On January 24, 2022 a
Motion-Secondary
was filed
involving a dispute between
Julie Kitahara,
and
Steven Aron,
for H90 - Housing - All Other
in the District Court of Fairfield County.
Preview
EXHIBIT 1
INVOICE
Invoice #: 15917
Date: 11-01-2022
Alan Hirsh Laura Lind
1675 York Avenue
Apt 31K
New York, NY 10128
RE:Laura Lind Alan Hirsh a.-Hirsh, Alan and Lind, Laura vs Gold, Lisa
Residential Security Deposit Issue
Landlord/Tenant Issue
Our File Number: 5123-20 KJL
Services Rendered
Date Staff Description Hours Rate Charges
10-27-20 KJL Meet with client (L. Lind) re security deposit dispute; review lease and 1.20 300.00 $360.00
communications; researching landlord; several emails exchanged with
clients L. Lind / A. Hirsh;
10-29-20 KJL Draft demand letter to landlord Lisa Gold; emails exchanged with clients 1.30 300.00 $390.00
(A. Hirsh / L. Lind) re demand letter, further documents and information
and Gold contact details; researching Lisa Gold's Florida addresses
finalize and send demand letter via email and Federal Express;
10-30-20 KJL Email exchanges with landlord (L. Gold) re demand letter; email 0.30 300.00 $90.00
exchanges with clients (A. Hirsh / L. Lind) re same and further handling;
10-31-20 KJL Email exchanges with landlord (L. Gold) and her counsel (H. Essner) 0.40 300.00 $120.00
regarding security deposit dispute; emails exchanged with clients (L.
Lind / A. Hirsh) re same and planned course of further handling;
11-02-20 KJL Draft Complaint for return of security deposit and double damages; 1.00 300.00 $300.00
11-03-20 KJL Meet with client (L. Lind) regarding case; review of text messages and 1.00 300.00 $300.00
photos supporting client's claim; resume drafting Complaint for return of
security deposit and payment of breakage fee; telecom with landlord's
counsel (H. Essner) regarding dispute;
11-05-20 KJL Teleconference with client (A. Hirsh) re status of discussions with 0.20 300.00 $60.00
landlord's counsel and further handling;
Page: 1
11-06-20 KJL Email exchanges with client (A. Hirsh) re broker and $7k breakage 1.20 300.00 $360.00
agreement, further dealings with landlord's counsel on settlement, case
filing; re-review text messages and photos; scanning / redacting photos
and messages; email to landlord's counsel (H. Essner) (bcc: clients)
providing claim supports and reiterating demand to return security
deposit;
11-09-20 KJL Email exchanges with clients (A. Hirsh / L. Lind) re communications with 0.20 300.00 $60.00
landlord's counsel and further handling;
;
11-10-20 KJL Email to landlord's counsel (H. Essner) regarding settlement; 0.10 300.00 $30.00
11-11-20 KJL Email exchanges with landlord's counsel (H. Essner) re security deposit 0.10 300.00 $30.00
dispute;
11-12-20 KJL Email exchanges with client (A. Hirsh) re status of dealings with 0.20 300.00 $60.00
landlord's counsel and commencement of lawsuit to recover security
deposit, etc.;
11-19-20 KJL Draft Complaint to seek recovery of security deposit and breakage fee; 1.00 300.00 $300.00
email exchanges with client (A. Hirsh) re same;
11-20-20 KJL Email exchanges with client (A. Hirsh) re draft Complaint and further 0.50 300.00 $150.00
handling; sign/execute and compile Complaint; draft and sign
Summons; email to process server for service on Gold in Boca Raton;
11-23-20 KJL Correspondence with process server regarding status of service on Lisa 0.20 300.00 $60.00
Gold; reviewing status of service on process server's web portal; email
exchanges with client (A. Hirsh) re status of case and further handling;
11-25-20 KJL Receive and review Affidavit of Service; save to file; email to client (A. 0.20 300.00 $60.00
Hirsh) advising of status and further handling;
11-27-20 KJL Receive and review process server's invoice for service on Lisa Gold; 0.10 300.00 $30.00
save to file;
11-28-20 KJL File action on Superior Court docket; 0.20 300.00 $60.00
12-02-20 KJL Receive and review communications from Gold counsel (H. Essner) 0.60 300.00 $180.00
providing claim supports for alleged property damage; acknowledge
emails; forward materials to client (A. Hirsh / L. Lind) and request
comments; ; numerous emails exchanged with
client (A. Hirsh) re landlord's claims, further handling;
12-03-20 KJL Email exchanges with clients (A. Hirsh / L. Lind) regarding Gold claims 0.20 300.00 $60.00
about property damage;
12-04-20 KJL Email exchanges with clients (A. Hirsh / L. Lind) re condition of property 0.20 300.00 $60.00
upon departure and time line of dispute / departure from Alden Street
property;
12-08-20 KJL Correspondence with clients (A. Hirsh / L. Lind) regarding case status, 0.20 300.00 $60.00
evidence denying landlord's claims, etc,;
12-14-20 KJL Email exchanges with client (A. Hirsh) re next steps; 0.10 300.00 $30.00
Page: 2
12-22-20 KJL Email to client (A. Hirsh) re case status and further handling; 0.10 300.00 $30.00
12-23-20 KJL Email received from client (A. Hirsh) re deadline and further handling; 0.10 285.00 $28.50
12-31-20 KJL Draft and file motion for default for failure to appear; arrange personal 0.50 300.00 $150.00
service of motion on defendant in Florida; email to client copy of motion;
01-04-21 KJL Receive and review update regarding service of motion for default on 0.10 300.00 $30.00
Gold in Florida;
01-06-21 KJL Receive and review affidavit of service for default motion served on 0.20 300.00 $60.00
defendant; save to file; electronically file affidavit; email to client (A.
Hirsh) re same;
01-08-21 KJL Email exchanges with client (A. Hirsh) re enforcement steps in FL; 0.10 300.00 $30.00
01-09-21 KJL Receive and review appearance from Gold counsel (H. Hirsch); 0.10 300.00 $30.00
01-13-21 KJL Email to landlord's counsel (H. Hirsch) regarding further case handling; 0.20 300.00 $60.00
email exchanges with client (A. Hirsh) re appearance by landlord's
counsel and further handling;
01-20-21 KJL Email received from landlord's counsel (H. Hirsch) regarding case; 0.10 300.00 $30.00
01-20-21 KJL Email exchanges with client (A. Hirsh) regarding status of dealings with 0.20 300.00 $60.00
landlord's attorney; email to landlord's attorney (H. Hirsch / A. Hirsch)
requesting comments;
01-22-21 KJL Teleconference with landlord's counsel (H. Hirsch) regarding case; email 0.40 300.00 $120.00
exchanges with client (A. Hirsh) re settlement; email to landlord's
counsel with settlement proposal; receive copy of landlord counsel email
to defendant re settlement; further email exchanges with client;
02-03-21 KJL Email exchanges wirh client (A. Hirsh) re status of settlement 0.20 300.00 $60.00
negotiations; email exchanges with landlord's counsel (H. Hirsch) re
same;
02-10-21 KJL Email exchanges with client (A. Hirsh) re landlord's position; email 0.20 300.00 $60.00
exchanges with landlord's counsel (H. Hirsch) re same;
02-12-21 KJL Receive and review email from landlord's counsel (H. Hirsh) re status of 0.10 300.00 $30.00
dealings with landlord and potential offer next week;
02-15-21 KJL Email received from client (A. Hirsh) re office visit and further case 0.10 300.00 $30.00
handling;
02-16-21 KJL Email to landlord's counsel (H. Hirsh) addressing points raised about 0.10 300.00 $30.00
notice of new address, early termination agreement and settlement;
02-17-21 KJL Email exchanges with client (A. Hirsh) reporting on status of dealings 0.10 300.00 $30.00
with landlord's counsel;
02-18-21 KJL Email exchanges with clients (A. Hirsh / L. Lind) regarding 0.20 300.00 $60.00
communications with landlord and further case handling;
Page: 3
02-23-21 KJL Teleconference with defendant's counsel (H. Hirsh) re position on 0.20 300.00 $60.00
lawsuit; email exchanges with client (H. Hirsh) re same and further
handling;
02-24-21 KJL Email received from client (A. Hirsh) re agents who will verify breakage 0.10 300.00 $30.00
fee agreement;
02-26-21 KJL Email exchanges with client (A. Hirsh) re follow up with agents, buyers 0.20 300.00 $60.00
and breakage agreement; review draft breakage agreement; save to file;
03-01-21 KJL Receive and review Answer with Special Defenses and Counterclaim 0.40 300.00 $120.00
from landlord' counsel; email to client (A. Hirsh / L. Lind) forwarding
pleading and requesting comments; researching effect of sale of house
on lease;
03-08-21 KJL Email exchange with client (A. Hirsh) re further handling; 0.10 300.00 $30.00
03-09-21 KJL Email exchanges with client (A. Hirsh) regarding telecom to discuss 0.10 300.00 $30.00
further case handling;
03-10-21 KJL Legal Research 1.50 300.00 $450.00
review of claim documents; telecom with client (A.
Hirsh) regarding further case handling / strategy; draft punch list of
follow up items for clients; email to clients (A. Hirsh / L. Lind) re same;
03-11-21 KJL Receive and review feedback from client (L. Lind) on points raised 0.30 300.00 $90.00
regarding landlord's Counterclaim; emails exchanged with clients (L. Lind
/ A. Hirsh) re same;
03-25-21 KJL Email received from landlord's counsel (H. Hirsh) re response to 0.10 300.00 $30.00
Counterclaim;
03-29-21 KJL Email to landlord's counsel (H. Hirsh) regarding response to 0.30 300.00 $90.00
Counterclaim; drafting Answer to Counterclaim and Reply to Special
Defenses;
03-30-21 KJL Draft Answer to Counterclaim; draft Reply to Special Defenses; email to 1.20 300.00 $360.00
clients forwarding Answer and Reply for review and comments; receive
and review client comments;
03-31-21 KJL Email exchanges with clients (A. Hirsh / L. Lind) re draft pleadings; 0.50 300.00 $150.00
revise, finalize and file / serve pleadings; email to landlord's counsel (H.
Hirsch) serving pleadings and addressing case;
04-08-21 KJL Receive and review Gold's Reply to Special Defenses to Counterclaim; 0.10 300.00 $30.00
04-09-21 KJL Email exchanges with SW re subpoenas; email exchanges with client (A. 0.20 300.00 $60.00
Hirsh) re case status and further handling;
04-15-21 KJL Email received from SW re subpoenas; 0.10 300.00 $30.00
04-15-21 SW Draft subpoenas for records from third party witnesses 1.50 250.00 $375.00
04-16-21 SW Draft Subpoenas 0.20 250.00 $50.00
Page: 4
04-16-21 KJL Receive and review draft subpoenas; edit subpoenas and return to SW; 0.30 300.00 $90.00
emails exchanged with client (A. Hirsh) re status and further handling;
04-19-21 Arrange process server to serve two parties; serveral emails with process 0.50 90.00 $45.00
server and Steven re service
04-19-21 SW Review subpoena's in advance of serving same. 0.40 250.00 $100.00
04-19-21 SW Draft notice to opposing counsel regarding service of subpoenas on 0.20 250.00 $50.00
third parties
04-19-21 SW Finalize and serve subpoenas 0.40 250.00 $100.00
04-19-21 KJL Conference with SW regarding subpoenas; receive and review SW emails 0.30 300.00 $90.00
with paralegal re service of subpoenas;
; email exchanges with SW regarding Notice of Subpoena; email
to client (A. Hirsh) advising status of subpoenas;
04-21-21 KJL Conference with SRW regarding Notice of Service of Subpoenas; receive 0.10 300.00 $30.00
SRW email to defense counsel service Notice of Service of Subpoenas;
04-23-21 KJL Email exchange with client (A. Hirsh) (cc: SRW) regarding status of 0.20 300.00 $60.00
subpoenas being served on realtor and home buyer and further case
handling;
04-27-21 KJL Email exchange with client (A. Hirsh) regarding Lisa Gold contact to 0.10 300.00 $30.00
realtor and status of service of subpoenas;
04-28-21 KJL Email exchanges with office regarding subpoenas; emails exchanged 0.20 300.00 $60.00
with client (A. Hirsh) re same;
04-29-21 KJL Email exchange with client (A. Hirsh) re subpoena served on realtor; 0.10 300.00 $30.00
05-03-21 KJL Receive and review emails from office re service of subpoenas; telecom 0.20 300.00 $60.00
to Jackie Davis re subpoena (left message for call back); email
exchanges with client (A. Hirsh) re Jackie Davis; conferring with SRW re
filing of affidavits of service;
05-05-21 KJL Teleconference with realtor (Jackie Davis) re subpoena (left message for 0.10 300.00 $30.00
call back); email exchanges with client (A. Hirsh) re efforts to contact
realtor;
05-24-21 KJL Teleconference with client (A. Hirsh) re status and further handling; 0.10 300.00 $30.00
06-10-21 KJL Conference with SRW regarding subpoenas and further efforts to obtain 0.10 300.00 $30.00
compliance;
06-11-21 SW Follow up with third party witnesses on failure to respond to subpoenas 0.70 250.00 $175.00
06-25-21 Locate potential phone number for Samantha Shea; attempt to contact 0.90 175.00 $157.50
Jackie Davis regarding subpoena
07-02-21 KJL Receive and review client email (A. Hirsh) re case status; 0.10 300.00 $30.00
Page: 5
07-06-21 KJL Correspondence with SRW re contact with client (A. Hirsh); 0.10 300.00 $30.00
07-07-21 KJL Teleconference with client (A. Hirsh) regarding case status; confer with 0.50 300.00 $150.00
SRW re further case handling; communicate with realtor (J. Davis) re
overdue subpoena response; communicate with buyer's counsel (K.
Costello) re overdue subpoena response from clients;
07-07-21 SW Review land records in connection with contacting buyers to obtain 0.20 250.00 $50.00
documentation of sale of 121 Alden
07-08-21 KJL Email exchanges with home buyer and their counsel re subpoena; email 0.20 300.00 $60.00
exchanges with SRW re same; email to clients re same;
07-09-21 KJL Conference with SRW regarding Certificate of Closed Pleadings and 0.20 300.00 $60.00
follow up on subpoenas; follow up email to realtor (J. Davis) (cc: clients /
SRW) regarding subpoena compliance; email exchanges with client (A.
Hirsh / L. Lind) (cc: SRW) regarding subpoenas and case status / further
handling;
07-09-21 SW Speak with buyer's attorney in connection with obtaining responses from 0.50 250.00 $125.00
them; file certificate of closed pleadings; contact caseflow regarding trial
date
07-10-21 KJL Receive and review email reply from realtor (J. Davis) regarding 0.10 300.00 $30.00
subpoena;
07-12-21 KJL Teleconference with client (A. Hirsh) re Jackie Davis; email to Jackie 0.10 300.00 $30.00
Davis;
07-13-21 KJL Receive and review SRW email addressing ability to seek and recover 0.10 300.00 $30.00
punitive damages and amending Complaint;
07-13-21 SW Research permissability of recovering punitive damages 0.60 250.00 $150.00
07-14-21 KJL Conference with SRW regarding further case handling including 0.40 300.00 $120.00
outstanding subpoenas and amendment of pleading
email to realtor (J. Davis) re
subpoena response; email exchanges with client (A. Hirsh) re status and
recommended further handling to amend complaint
;
07-15-21 KJL Email exchanges with realtor (J. Davis) regarding subpoena compliance; 0.30 300.00 $90.00
telecom with J. Davis; email exchanges with client (A. Hirsh) (cc: SRW)
regaridng dealings with Jackie Davis;
07-19-21 KJL Conference with SRW regarding further handling of subpoenas and 0.20 300.00 $60.00
litigation; email exchanges with client (A. Hirsh) re strategy to amend
Complaint and put pressure on Gold;
07-22-21 SW Research standard for leave to amend complaint upon presentation of 1.80 250.00 $450.00
new information in connection with drafting same; draft motion for leave
to amend
07-22-21 SW Research causes of action 1.30 250.00 $325.00
07-22-21 SW Continue drafting motion for leave to amend 0.50 250.00 $125.00
Page: 6
07-22-21 SW Speak with attorney for purchasers in connection with obtaining 0.20 250.00 $50.00
responsive information to subpoena
07-26-21 SW Contact Debit Moris from attorney for buyer regarding production of file 0.10 250.00 $25.00
07-26-21 KJL Email received from client (A. Hirsh) re status and further efforts; receive 0.10 300.00 $30.00
and review status update on drafting status from SRW;
07-28-21 KJL Email to client (A. Hirsh) re status of motion to amend Complaint; email 0.10 300.00 $30.00
exchanges with SRW re same;
07-30-21 SW Research and review case law on motion for leave to amend standard in 0.60 250.00 $150.00
connection with drafting same.
07-30-21 SW Continue drafting motion for leave to amend complaint 1.00 250.00 $250.00
07-30-21 SW Research elements of newly discovered causes of action and draft 1.60 250.00 $400.00
amended complaint to include same
08-03-21 KJL Email exchanges with client (A. Hirsh) (cc: SRW) re status of motion to 0.10 300.00 $30.00
amend complaint;
08-10-21 KJL Review of draft motion to amend Complaint and amended Complaint; 0.50 300.00 $150.00
return drafts to SRW with edits for finalization and filing; receive and
review SRW email to opposing counsel (H. Hirsch) forwarding motion
papers;
08-10-21 SW Finalize and file request for leave to amend and proposed amended 0.40 250.00 $100.00
complaint
08-12-21 SW Correspond with clients regarding case update re Motion for Leave to 0.10 250.00 $25.00
Amend
08-12-21 KJL Receive and review email communications by SRW and client (A. Hirsh) 0.10 300.00 $30.00
regarding case status and next steps;
08-13-21 KJL Email to client (A. Hirsh) regarding case status and expected further case 0.10 300.00 $30.00
developments / timetable;
08-24-21 KJL Receive and review defendant's objection to motion to amend complaint; 0.20 300.00 $60.00
09-01-21 KJL Conference with SRW regarding court hearing on motion to amend 0.10 300.00 $30.00
complaint and further handling;
09-02-21 KJL Review of defendant's objection to motion for leave to file amended 0.30 300.00 $90.00
complaint; email exchanges with SRW regarding reply to objection and
handling of court hearing; email exchanges with client (A. Hirsh) (cc:
SRW) re case status and further handling;
09-03-21 KJL Review of draft reply to defendant's opposition to motion to amend 0.30 300.00 $90.00
complaint; email exchanges with SRW re same;
09-03-21 SW Draft reply to objection to leave to amend; 0.90 250.00 $225.00
Page: 7
09-07-21 SW Finalize and file reply to objection to motion for leave to amend; 0.30 250.00 $75.00
09-08-21 SW Preapre for hearing on motion for leave to amend; attend hearing on 0.50 250.00 $125.00
motion for leave to amend;
09-08-21 KJL Conference with SRW regarding today's hearing and mediation and 0.10 300.00 $30.00
further handling;
09-09-21 KJL Receive and review SRW email to defense counsel (H. Hirsh) regarding 0.10 300.00 $30.00
recent filing; receive and review defendant's requests to admit; save to
file;
09-15-21 KJL Email to clients (A. Hirsh / L. Lind) forwarding request for admissions for 0.40 285.00 $114.00
review and comment; calendar reply deadline; receive SRW email
advising on next week's mediation / hearing; telecom with client (A.
Hirsh) re mediation and pending motion; discuss further handling with
SRW;
09-20-21 KJL Conference with SRW regarding position for mediation; confer with SRW 0.20 300.00 $60.00
regarding outcome of hearing on motion to amend and further case
handling;
09-20-21 SW Call with Alan Hirsh in advance of hearing 0.10 250.00 $25.00
09-20-21 SW Attend at hearing on motion for leave to amend; 0.40 250.00 $100.00
09-20-21 SW Prepare for hearing on motion for leave to amend; 0.70 250.00 $175.00
09-24-21 KJL Email to clients (A. Hirsh / L. Lind) requesting comments on requests to 0.10 300.00 $30.00
admit;
09-27-21 KJL Email exchanges with clients (A. Hirsh / L. Lind) regarding requested 0.20 300.00 $60.00
admissions; confer with SRW regarding Amended Complaint; receive and
review email to defendant's counsel serving Amended Complaint;
09-27-21 SW Finalize and file amended complaint; correspond with counsel for 0.20 250.00 $50.00
defendant regarding same;
09-28-21 KJL Email exchanges with clients (L. Lind / A. Hirsh) (cc: SRW) regarding 0.10 300.00 $30.00
Monday meeting to review defendant's requested admissions; diary
meeting in calendar;
10-04-21 KJL Draft responses to requests for admission; meet with clients (L. Lind / A. 1.20 300.00 $360.00
Hirsh) and SRW to review defendant's requested admissions; emails
exchanged with client (L. Lind) ; revising
responses to requested admissions; emails exchanged with SRW re
responses;
10-05-21 KJL Conference with SRW regarding admissions; email to clients (L. Lind / A. 0.10 300.00 $30.00
Hirsh) (cc: SRW) ;
10-06-21 KJL Email exchanges with clients (L. Lind / A. Hirsh) and SRW 0.10 300.00 $30.00
;
10-07-21 KJL DISCOVERY - execute Verification pages and send to SRW; communicate 0.10 300.00 $30.00
with SRW regarding discovery;
Page: 8
10-07-21 SW Finalize responses to Request to Admit and file same; communicate with 0.40 250.00 $100.00
defense counsel regarding responses to request to admit; draft notice of
response to requests to admit and file same with court;
10-08-21 SW Finalize and file notice of response to request to admit; communicate 0.20 250.00 $50.00
with counsel for defendant regarding requests to admit;
10-08-21 SW Review pleadings, documents, and correspondence in connection with 1.60 250.00 $400.00
drafting discovery requests; draft discovery requests;
10-11-21 SW Review practice book and statutory requirements for pleading to an 0.20 250.00 $50.00
amended complaint in connection with ascertaining appropriate
response to Defendant's answer, special defenses, and counterclaim;
10-13-21 KJL Receive and review Defendant's Answer to Amended Complaint with 0.30 300.00 $90.00
Special Defenses and Counterclaim; save to file; email to Gold counsel
(H. Hirsh); email exchanges and conferring with SRW re next steps; email
exchange with clients (H. Hirsh / L. Lind) forwarding Gold's Answer to
Amended Complaint with Counterclaim and addressing next steps;
10-21-21 KJL Receive and review client inquiry (A. Hirsh) restatus; 0.10 300.00 $30.00
10-23-21 KJL Email to SRW requesting update on discovery status for client update; 0.10 300.00 $30.00
10-25-21 KJL Correspondence with SRW regarding discovery, request to revise and 0.10 285.00 $28.50
update to client;
10-25-21 SW Review Amended Answer and Special Defenses in connection with 2.00 250.00 $500.00
drafting responsive pleading to same; draft response to amended
answer and special defenses and counterclaim; draft updated discovery
requests to be served on Lisa Gold;
10-27-21 KJL Review of Request to Revise; communicate wiith SRW re same; 0.10 300.00 $30.00
10-27-21 SW Draft request to revise amended answer and counterclaim; 1.00 250.00 $250.00
10-28-21 KJL Receive and review service of request to revise on Gold's counsel; 0.10 300.00 $30.00
10-28-21 SW Revise request to revise, finalize and file same; correspond with Harry 0.30 250.00 $75.00
Hirsch regarding service of same;
10-29-21 KJL Email exchanged with clients (A. Hirsh / L. Lind) re status update - 0.10 300.00 $30.00
request to revise served on Gold's counsel and discovery to be
propounded;
11-03-21 KJL Email received from SRW with draft discovery requests; 0.10 300.00 $30.00
11-07-21 SW Finalize and serve discovery requests on Lisa Gold; file notice of service 0.40 250.00 $100.00
with the court; correspond with attorney for Lisa Gold regarding same;
11-08-21 KJL Email exchanges with client (A. Hirsh) re case status; email exchanges 0.10 300.00 $30.00
with SRW re same;
11-29-21 KJL Receive and review defendant's responses and objection to request to 0.20 300.00 $60.00
revise; receive and review invite for hearing on request to revise; email
received from client (A. Hirsh) re same;
Page: 9
12-13-21 KJL Email received from client (A. Hirsh) re upcoming hearing; 0.10 300.00 $30.00
12-14-21 KJL Receive and review SRW communications with client (A. Hirsh) re 0.10 300.00 $30.00
tomorrow's hearing; briefly confer with SRW re hearing coverage;
12-15-21 KJL Conference with SRW re hearing outcome on request to revise and next 0.20 300.00 $60.00
steps in case; receive and review SRW email exchanges with client (A.
Hirsh / L. Lind) re status and next steps;
12-15-21 SW Attend at hearing on request to revise; draft e-mail to Laura and Alan 0.50 250.00 $125.00
regarding outcome of hearing and next steps;
12-15-21 SW Prepare for hearing on request to revise; 0.50 250.00 $125.00
12-24-21 KJL Receive and review landlord's discovery responses; email exchanges 0.10 300.00 $30.00
with SRW re discovery responses and objections;
12-27-21 KJL Receive and review landlord's revised Answer, Special Defenses and 0.10 300.00 $30.00
Counterclaim and objections to discovery;
12-30-21 KJL Correspondence with SRW regarding further case handling - response to 0.10 300.00 $30.00
Counterclaim, resolving landlord's objections to discovery and
propounding additional discovery on alleged counterclaims;
01-05-22 KJL Email received from client (A. Hirsh) re status; 0.10 300.00 $30.00
01-06-22 KJL Email exchanges with client (A. Hirsh / L. Lind) (cc: SRW) regarding case 0.20 300.00 $60.00
status, trial date, etc.;
01-11-22 KJL Receive and review SRW emails with clients (A. Hirsh / L. Lind) re review 0.10 300.00 $30.00
of discovery responses;
01-11-22 SW Correspond with Laura and Alan regarding discovery responses; 0.10 250.00 $25.00
01-11-22 SW Speak with Alan regarding discovery responses and next steps in 0.20 250.00 $50.00
pushing matter towards resolution;
01-11-22 SW Review discovery requests from Lisa Gold; Draft objections to discovery 1.40 250.00 $350.00
requests; draft initial responses to discovery requests;
01-14-22 SW Meet with Laura and Alan regarding answers to discovery requests; 0.50 250.00 $125.00
01-14-22 KAB Notarize Plaintiff's Certification 0.10 90.00 $9.00
02-16-22 SW Review correspondence from Harry Hirsh regarding revised answer and 0.10 250.00 $25.00
special defenses;
02-16-22 SW Finalize and file Objections to Discovery requests; finalize and sent 0.80 250.00 $200.00
responses to discovery requests to attorney for Lisa Gold; Correspond
with Harry Hirsch regarding same
02-17-22 KJL Receive and review Court invite for remote hearing on Order for 0.10 300.00 $30.00
Compliance; receive email from client (A. Hirsh) re same;
Page: 10
02-23-22 SW Correspond with Alan Hirsh and Laura Lind regarding scheduled 0.10 250.00 $25.00
mediation hearing;
03-17-22 SW Review revised answer, special defense, and counterclaim filed by Lisa 1.20 250.00 $300.00
Gold in connection with determining compliance of same with court
ordered revisions; draft responsive pleading to revised answer, special
defense, and counterclaim;
03-25-22 KJL Receive and review SRW email exchanges with client (A. Hirsh) re case 0.10 300.00 $30.00
status; receive and review SRW email exchanges with opposing counsel
(H. Hirsch) re Monday's court conference; receive and review
continuance file by SRW;
03-25-22 SW Correspond with Alan regarding status of matter; draft motion to 0.40 250.00 $100.00
continue March 28, 2022 hearing pending resolution of discovery
disputes; correspond with Harry Hirsch regarding motion filed with Court;
03-25-22 SW Correspond with Harry Hirsch regarding upcoming hearing and 0.10 250.00 $25.00
discussion of outstanding discovery disputes;
03-25-22 SW Contact court regarding motion for continuance; 0.10 250.00 $25.00
03-28-22 SW Attend at hearing on motion to compel; 0.20 250.00 $50.00
03-28-22 SW Review responses to discovery request in preparation for hearing on 0.20 250.00 $50.00
discovery dispute;
04-05-22 SW Engage in good faith discovery resolution with Harry Hirsch; 0.50 250.00 $125.00
04-05-22 SW Review discovery disputes in advance of good faith discussion with 0.50 250.00 $125.00
Harry Hirsch regarding same;
05-18-22 KJL Receive and review client email (A. Hirsh) re case status; 0.10 300.00 $30.00
05-19-22 KJL Receive and review SRW case update to client (A. Hirsh); receive and 0.20 300.00 $60.00
review SRW email to landlord's counsel (A. Hirsh) re discovery issues;
05-19-22 SW Correspond with Alan and Linda regarding status of case; review status 1.30 250.00 $325.00
of pleadings and correspondence with Harry Hirsch in connection with
obtaining discovery compliance from Lisa Gold; Draft corrspondence
with Harry Hirsch regarding outstanding discovery compliance;
06-14-22 SW Correspond with Harry Hirsch regarding outstanding production; 0.10 250.00 $25.00
06-21-22 SW Contact Harry Hirsch regarding status conference with Court for June 22, 0.10 250.00 $25.00
2022;
06-21-22 SW Correspond with clerk of court regarding status conference scheduled 0.10 250.00 $25.00
fo4 6/22/2022;
06-22-22 KJL Receive and review disclosures from landlord re party communications; 0.10 300.00 $30.00
06-27-22 KJL Email exchanges with SRW regarding review of landlord's disclosures 0.10 300.00 $30.00
and further case handling;
Page: 11
06-28-22 KJL Receive court notice for Trial Order; conferring with SRW re further case 0.10 300.00 $30.00
handling;
06-29-22 SW Correspond with Alan Hirsh regarding status of the matter; 0.10 250.00 $25.00
07-01-22 KJL Receive and review SRW email to opposing counsel (H. Hirsch) re trial 0.20 300.00 $60.00
scheduled by court; communicate with SRW re further case handling;
review motion for continuance of trial;
07-05-22 SW Review production from Harry Hirsch, attorney for Lisa Gold, in 0.70 250.00 $175.00
connection with determining relevance and compliance with production
requests; correspond with Alan Hirsh and Laura Lind
07-05-22 KJL Review email exchanges by SRW and defense counsel re defendant's 0.20 300.00 $60.00
disclosures; review SRW communications with clients (A. Hirsh / L. Lind)
re case status and trial;
07-07-22 KJL Receive defense counsel email re further efforts with client to disclose all 0.10 300.00 $30.00
documentation;
07-20-22 KJL Receive and review defendant's motion to allow witnesses to appear for 0.10 300.00 $30.00
trial via remote means;
07-21-22 SW Correspond with Laura Lind and Alan Hirsh regarding upcoming hearing; 0.10 250.00 $25.00
07-21-22 KJL Review SRW emails with clients regarding hearing / trial on August 3 and 0.20 300.00 $60.00
preparation session; review caseflow request filed by defense counsel
requesting remote hearing attendance;
07-22-22 KJL Review SRW email exchanges with clients (A. Hirsh / L. Lind) re trial 0.10 300.00 $30.00
preparation;
07-25-22 KJL Confer with SRW regarding defendant's motion to allow witness to 0.70 300.00 $210.00
remotely testify and trial preparation;
07-26-22 KJL Edit direct and cross-examinations drafted by SRW; meet with clients (A. 3.00 300.00 $900.00
Hirsh / L. Lind) and SRW in preparation for trial next week; receive and
review defendant's trial brief; discuss with SRW; reviewing claim
documents / evidence and caselaw;
07-26-22 SW Prepare direct examination of Laura Lind, Alan Hirsh, and cross 3.00 250.00 $750.00
examination of Lisa Gold in preparation for trial on August 3, 2020;
07-26-22 SW Meet with Laura Lind and Alan Hirsh regarding preparation for trial on 1.50 250.00 $375.00
August 3, 2022;
07-26-22 SW Review Trial Management Report filed by Harry Hirsch, counsel for 1.00 250.00 $250.00
Defendant, in preparation for pre-trial conference on July 27, 2022;
develop trial strategy with KJL;
07-27-22 KJL Draft Plaintiffs' Trial Brief; conferring with SRW; editing / revising 2.50 300.00 $750.00
Plaintiffs' Trial Brief; attend at remote pre-trial hearing with SRW; confer
with SRW following hearing; researching
; review SRW communications with clients (A. Hirsh / L. Lind)
re trial; receive defendant's amended witness list;
Page: 12
07-27-22 SW Revise Trial Management report in advance of submitting same to Court; 0.50 250.00 $125.00
07-27-22 SW Finalize and file Pre-Trial Memorandum in advance of hearing; 0.20 250.00 $50.00
07-27-22 SW Speak with ; 0.20 250.00 $50.00
07-27-22 SW Attend at pre-trial conference; 0.50 250.00 $125.00
07-29-22 SW Review correspondence with Harry Hirsch regarding request for 1.50 250.00 $375.00
continuance; review motion for continuance filed by Harry Hirsch; review
practice book regarding basis for continuance; draft objection to motion
for continuance;
07-29-22 KJL Receive defense counsel (H. Hirsh) request for adjournment based on 1.50 300.00 $450.00
alleged unavailability of witness; confer with SRW; communication with
H. Hirsh regarding adjournment request; researching
; researching
review / research CT Practice Book sections on requested
trial adjournments; review and edit draft Objection; review Court Order
granting continuance; conferring with SRW; review
;
08-01-22 KJL Communicate with SRW and clients (A. Hirsh / L. Lind) re new trial date; 0.20 300.00 $60.00
diary trial date in calendar; review
; confer with SRW re further case handling / trial
preparation;
08-01-22 SW Review court calendar in connection with determining new trial date; 0.20 250.00 $50.00
correspond with Alan and Laura regarding new trial date; correspond
with ;
08-03-22 KJL Email exchanges with clients (A. Hirsh / L. Lind) re moving trial date to 0.20 300.00 $60.00
October; email to ;
08-08-22 KJL Email to defense counsel (H. Hirsch / A. Hirsch) (cc: SRW) seeking 0.10 300.00 $30.00
consent for trial continuance to middle of October;
08-09-22 KJL Email exchanges with defense counsel (H. Hirsch / A. Hirsch) (cc: SRW) 0.40 300.00 $120.00
re trial date adjustment; email exchanges with clients (A. Hirsh / L. Lind)
(cc: SRW) re same; email exchanges
; discuss Lisa Gold
apparent witness tampering with SRW;
08-10-22 KJL Email exchanges with clients (L. Lind / A. Hirsh) regarding adjournment 0.80 300.00 $240.00
of trial date and necessity to attend trial; draft and file continuance
motion for new trial date; serve continuance motion on defense counsel
(H. Hirsch / A. Hirsch); email exchanges ;
email exchanges with SRW re follow up on subpoenas; confer with SRW
re Laura Gold witness tampering and further case handling; receive
receive Tancredi-Gold
communications; research witness tampering in state of CT;
08-10-22 SW Correspond with ; 0.20 250.00 $50.00
08-11-22 SW Review 0.30 250.00 $75.00
08-11-22 KJL Discuss with SRW 0.10 300.00 $30.00
Page: 13
08-12-22 KJL Email exchanges with SRW re adjourned trial date; 0.10 300.00 $30.00
08-15-22 KJL Review SRW messages with clients (A. Hirsh / L. Lind) and non-party 0.20 300.00 $60.00
(Mark Tancredi) re new trial date; communicate with SRW
;
08-18-22 KJL Receive and review email ; 0.10 300.00 $30.00
08-23-22 KJL Email exchanges with SRW re , subpoena follow up and 0.20 300.00 $60.00
further case handling / strategy; communicate with SRW re further
handling;
10-18-22 KJL Review file in preparation for upcoming trial; communicate with client (A. 0.30 300.00 $90.00
Hirsh / L. Lind) regarding case status, trial preparation, etc..;
10-19-22 KJL Receive updated witness list from defense counsel; email to defense 0.30 300.00 $90.00
counsel (H. Hirsh) advising Mark Tancredi will be called at trial and
providing communications showing defendant tried to silence Tancredi
from testifying; communicate with SRW re possible motion to preclude
client's ex-husband from testifying at trial;
10-21-22 KJL Email exchanges with clients (A. Hirsh / L. Lind) (cc: SRW) regarding trial 0.10 300.00 $30.00
preparation meeting next week;
10-25-22 KJL Discuss case and upcoming trial with SRW; 0.20 300.00 $60.00
10-26-22 KJL Communicate with SRW re trial preparation; reviewing file; revising direct 1.50 300.00 $450.00
examinations for clients; meet with clients for trial preparation; email
exchanges with SRW re Mark Tancredi;
10-26-22 SW ; 0.50 250.00 $125.00
research basis for motion for protective order to preclude David Fresne
from testifying; contact States Attorney and Attorney Generals office
regarding reporting misconduct of Lisa Gold with respect to witness
tampering; renew preparation for trial;
10-26-22 SW Prepare for trial and meet with Laura Lind and Alan Hirsh; 2.00 250.00 $500.00
10-27-22 KJL Receive defendant's motion in limine to preclude Mark Tancredi; email 2.00 300.00 $600.00
exchanges with defense counsel (H. Hirsh) re same; discuss opposition
with SRW and affirmative motion in limine to preclude David Fresne;
drafting opposition to defendant's motion in limine; review SRW
communications with Mark Tancredi; review / edit draft motion to
preclude David Fresen; receive and review defendant's Caseflow Request
re remote testimony of two witnesses;
10-27-22 SW Review amended trial witness list in connection with drafting motion to 2.60 250.00 $650.00
preclude; review correspondence between Laura Lind and Lisa Gold in
connection with drafting motion to preclude; draft motion to preclude;
10-28-22 SW Correspond with ; 0.10 250.00 $25.00
10-28-22 KJL Email exchanges with SRW re ; review 0.20 300.00 $60.00
SRW communications ; review SRW communications
with client (L. Lind) regarding David Fresne; receive email from defense
counsel (H. Hirsch) regarding witnesses for remote testimony; review
motion in limine filed to preclude testimony of David Fresne;
Page: 14
10-28-22 SW Speak with 0.30 250.00 $75.00
draft subpoena for attendance of Mark Tancredi;
10-28-22 SW Finalize and file motion to preclude David Fresne; 0.70 250.00 $175.00
10-31-22 KJL Confer with SRW re trial preparation; email to defense counsel (H. Hirsh) 1.50 300.00 $450.00
regarding witnesses he seeks to be allowed to testify via remote means;
reviewing file and revising direct exam for Laura Lind; drafting exam for
Lisa Gold; organizing trial exhibits to be uploaded to court's system;
reviewing file;
11-01-22 KJL Trial preparation - drafting / revising direct ex
Document Filed Date
April 09, 2024
Case Filing Date
January 24, 2022
Category
H90 - Housing - All Other
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
EXHIBIT 1 INVOICE Invoice #: 15917 Date: 11-01-2022 Alan Hirsh Laura Lind 1675 York Avenue Apt 31K New York, NY 10128 RE:Laura Lind Alan Hirsh a.-Hirsh, Alan and Lind, Laura vs Gold, Lisa Residential Security Deposit Issue Landlord/Tenant Issue Our File Number: 5123-20 KJL Services Rendered Date Staff Description Hours Rate Charges 10-27-20 KJL Meet with client (L. Lind) re security deposit dispute; review lease and 1.20 300.00 $360.00 communications; researching landlord; several emails exchanged with clients L. Lind / A. Hirsh; 10-29-20 KJL Draft demand letter to landlord Lisa Gold; emails exchanged with clients 1.30 300.00 $390.00 (A. Hirsh / L. Lind) re demand letter, further documents and information and Gold contact details; researching Lisa Gold's Florida addresses finalize and send demand letter via email and Federal Express; 10-30-20 KJL Email exchanges with landlord (L. Gold) re demand letter; email 0.30 300.00 $90.00 exchanges with clients (A. Hirsh / L. Lind) re same and further handling; 10-31-20 KJL Email exchanges with landlord (L. Gold) and her counsel (H. Essner) 0.40 300.00 $120.00 regarding security deposit dispute; emails exchanged with clients (L. Lind / A. Hirsh) re same and planned course of further handling; 11-02-20 KJL Draft Complaint for return of security deposit and double damages; 1.00 300.00 $300.00 11-03-20 KJL Meet with client (L. Lind) regarding case; review of text messages and 1.00 300.00 $300.00 photos supporting client's claim; resume drafting Complaint for return of security deposit and payment of breakage fee; telecom with landlord's counsel (H. Essner) regarding dispute; 11-05-20 KJL Teleconference with client (A. Hirsh) re status of discussions with 0.20 300.00 $60.00 landlord's counsel and further handling; Page: 1 11-06-20 KJL Email exchanges with client (A. Hirsh) re broker and $7k breakage 1.20 300.00 $360.00 agreement, further dealings with landlord's counsel on settlement, case filing; re-review text messages and photos; scanning / redacting photos and messages; email to landlord's counsel (H. Essner) (bcc: clients) providing claim supports and reiterating demand to return security deposit; 11-09-20 KJL Email exchanges with clients (A. Hirsh / L. Lind) re communications with 0.20 300.00 $60.00 landlord's counsel and further handling; ; 11-10-20 KJL Email to landlord's counsel (H. Essner) regarding settlement; 0.10 300.00 $30.00 11-11-20 KJL Email exchanges with landlord's counsel (H. Essner) re security deposit 0.10 300.00 $30.00 dispute; 11-12-20 KJL Email exchanges with client (A. Hirsh) re status of dealings with 0.20 300.00 $60.00 landlord's counsel and commencement of lawsuit to recover security deposit, etc.; 11-19-20 KJL Draft Complaint to seek recovery of security deposit and breakage fee; 1.00 300.00 $300.00 email exchanges with client (A. Hirsh) re same; 11-20-20 KJL Email exchanges with client (A. Hirsh) re draft Complaint and further 0.50 300.00 $150.00 handling; sign/execute and compile Complaint; draft and sign Summons; email to process server for service on Gold in Boca Raton; 11-23-20 KJL Correspondence with process server regarding status of service on Lisa 0.20 300.00 $60.00 Gold; reviewing status of service on process server's web portal; email exchanges with client (A. Hirsh) re status of case and further handling; 11-25-20 KJL Receive and review Affidavit of Service; save to file; email to client (A. 0.20 300.00 $60.00 Hirsh) advising of status and further handling; 11-27-20 KJL Receive and review process server's invoice for service on Lisa Gold; 0.10 300.00 $30.00 save to file; 11-28-20 KJL File action on Superior Court docket; 0.20 300.00 $60.00 12-02-20 KJL Receive and review communications from Gold counsel (H. Essner) 0.60 300.00 $180.00 providing claim supports for alleged property damage; acknowledge emails; forward materials to client (A. Hirsh / L. Lind) and request comments; ; numerous emails exchanged with client (A. Hirsh) re landlord's claims, further handling; 12-03-20 KJL Email exchanges with clients (A. Hirsh / L. Lind) regarding Gold claims 0.20 300.00 $60.00 about property damage; 12-04-20 KJL Email exchanges with clients (A. Hirsh / L. Lind) re condition of property 0.20 300.00 $60.00 upon departure and time line of dispute / departure from Alden Street property; 12-08-20 KJL Correspondence with clients (A. Hirsh / L. Lind) regarding case status, 0.20 300.00 $60.00 evidence denying landlord's claims, etc,; 12-14-20 KJL Email exchanges with client (A. Hirsh) re next steps; 0.10 300.00 $30.00 Page: 2 12-22-20 KJL Email to client (A. Hirsh) re case status and further handling; 0.10 300.00 $30.00 12-23-20 KJL Email received from client (A. Hirsh) re deadline and further handling; 0.10 285.00 $28.50 12-31-20 KJL Draft and file motion for default for failure to appear; arrange personal 0.50 300.00 $150.00 service of motion on defendant in Florida; email to client copy of motion; 01-04-21 KJL Receive and review update regarding service of motion for default on 0.10 300.00 $30.00 Gold in Florida; 01-06-21 KJL Receive and review affidavit of service for default motion served on 0.20 300.00 $60.00 defendant; save to file; electronically file affidavit; email to client (A. Hirsh) re same; 01-08-21 KJL Email exchanges with client (A. Hirsh) re enforcement steps in FL; 0.10 300.00 $30.00 01-09-21 KJL Receive and review appearance from Gold counsel (H. Hirsch); 0.10 300.00 $30.00 01-13-21 KJL Email to landlord's counsel (H. Hirsch) regarding further case handling; 0.20 300.00 $60.00 email exchanges with client (A. Hirsh) re appearance by landlord's counsel and further handling; 01-20-21 KJL Email received from landlord's counsel (H. Hirsch) regarding case; 0.10 300.00 $30.00 01-20-21 KJL Email exchanges with client (A. Hirsh) regarding status of dealings with 0.20 300.00 $60.00 landlord's attorney; email to landlord's attorney (H. Hirsch / A. Hirsch) requesting comments; 01-22-21 KJL Teleconference with landlord's counsel (H. Hirsch) regarding case; email 0.40 300.00 $120.00 exchanges with client (A. Hirsh) re settlement; email to landlord's counsel with settlement proposal; receive copy of landlord counsel email to defendant re settlement; further email exchanges with client; 02-03-21 KJL Email exchanges wirh client (A. Hirsh) re status of settlement 0.20 300.00 $60.00 negotiations; email exchanges with landlord's counsel (H. Hirsch) re same; 02-10-21 KJL Email exchanges with client (A. Hirsh) re landlord's position; email 0.20 300.00 $60.00 exchanges with landlord's counsel (H. Hirsch) re same; 02-12-21 KJL Receive and review email from landlord's counsel (H. Hirsh) re status of 0.10 300.00 $30.00 dealings with landlord and potential offer next week; 02-15-21 KJL Email received from client (A. Hirsh) re office visit and further case 0.10 300.00 $30.00 handling; 02-16-21 KJL Email to landlord's counsel (H. Hirsh) addressing points raised about 0.10 300.00 $30.00 notice of new address, early termination agreement and settlement; 02-17-21 KJL Email exchanges with client (A. Hirsh) reporting on status of dealings 0.10 300.00 $30.00 with landlord's counsel; 02-18-21 KJL Email exchanges with clients (A. Hirsh / L. Lind) regarding 0.20 300.00 $60.00 communications with landlord and further case handling; Page: 3 02-23-21 KJL Teleconference with defendant's counsel (H. Hirsh) re position on 0.20 300.00 $60.00 lawsuit; email exchanges with client (H. Hirsh) re same and further handling; 02-24-21 KJL Email received from client (A. Hirsh) re agents who will verify breakage 0.10 300.00 $30.00 fee agreement; 02-26-21 KJL Email exchanges with client (A. Hirsh) re follow up with agents, buyers 0.20 300.00 $60.00 and breakage agreement; review draft breakage agreement; save to file; 03-01-21 KJL Receive and review Answer with Special Defenses and Counterclaim 0.40 300.00 $120.00 from landlord' counsel; email to client (A. Hirsh / L. Lind) forwarding pleading and requesting comments; researching effect of sale of house on lease; 03-08-21 KJL Email exchange with client (A. Hirsh) re further handling; 0.10 300.00 $30.00 03-09-21 KJL Email exchanges with client (A. Hirsh) regarding telecom to discuss 0.10 300.00 $30.00 further case handling; 03-10-21 KJL Legal Research 1.50 300.00 $450.00 review of claim documents; telecom with client (A. Hirsh) regarding further case handling / strategy; draft punch list of follow up items for clients; email to clients (A. Hirsh / L. Lind) re same; 03-11-21 KJL Receive and review feedback from client (L. Lind) on points raised 0.30 300.00 $90.00 regarding landlord's Counterclaim; emails exchanged with clients (L. Lind / A. Hirsh) re same; 03-25-21 KJL Email received from landlord's counsel (H. Hirsh) re response to 0.10 300.00 $30.00 Counterclaim; 03-29-21 KJL Email to landlord's counsel (H. Hirsh) regarding response to 0.30 300.00 $90.00 Counterclaim; drafting Answer to Counterclaim and Reply to Special Defenses; 03-30-21 KJL Draft Answer to Counterclaim; draft Reply to Special Defenses; email to 1.20 300.00 $360.00 clients forwarding Answer and Reply for review and comments; receive and review client comments; 03-31-21 KJL Email exchanges with clients (A. Hirsh / L. Lind) re draft pleadings; 0.50 300.00 $150.00 revise, finalize and file / serve pleadings; email to landlord's counsel (H. Hirsch) serving pleadings and addressing case; 04-08-21 KJL Receive and review Gold's Reply to Special Defenses to Counterclaim; 0.10 300.00 $30.00 04-09-21 KJL Email exchanges with SW re subpoenas; email exchanges with client (A. 0.20 300.00 $60.00 Hirsh) re case status and further handling; 04-15-21 KJL Email received from SW re subpoenas; 0.10 300.00 $30.00 04-15-21 SW Draft subpoenas for records from third party witnesses 1.50 250.00 $375.00 04-16-21 SW Draft Subpoenas 0.20 250.00 $50.00 Page: 4 04-16-21 KJL Receive and review draft subpoenas; edit subpoenas and return to SW; 0.30 300.00 $90.00 emails exchanged with client (A. Hirsh) re status and further handling; 04-19-21 Arrange process server to serve two parties; serveral emails with process 0.50 90.00 $45.00 server and Steven re service 04-19-21 SW Review subpoena's in advance of serving same. 0.40 250.00 $100.00 04-19-21 SW Draft notice to opposing counsel regarding service of subpoenas on 0.20 250.00 $50.00 third parties 04-19-21 SW Finalize and serve subpoenas 0.40 250.00 $100.00 04-19-21 KJL Conference with SW regarding subpoenas; receive and review SW emails 0.30 300.00 $90.00 with paralegal re service of subpoenas; ; email exchanges with SW regarding Notice of Subpoena; email to client (A. Hirsh) advising status of subpoenas; 04-21-21 KJL Conference with SRW regarding Notice of Service of Subpoenas; receive 0.10 300.00 $30.00 SRW email to defense counsel service Notice of Service of Subpoenas; 04-23-21 KJL Email exchange with client (A. Hirsh) (cc: SRW) regarding status of 0.20 300.00 $60.00 subpoenas being served on realtor and home buyer and further case handling; 04-27-21 KJL Email exchange with client (A. Hirsh) regarding Lisa Gold contact to 0.10 300.00 $30.00 realtor and status of service of subpoenas; 04-28-21 KJL Email exchanges with office regarding subpoenas; emails exchanged 0.20 300.00 $60.00 with client (A. Hirsh) re same; 04-29-21 KJL Email exchange with client (A. Hirsh) re subpoena served on realtor; 0.10 300.00 $30.00 05-03-21 KJL Receive and review emails from office re service of subpoenas; telecom 0.20 300.00 $60.00 to Jackie Davis re subpoena (left message for call back); email exchanges with client (A. Hirsh) re Jackie Davis; conferring with SRW re filing of affidavits of service; 05-05-21 KJL Teleconference with realtor (Jackie Davis) re subpoena (left message for 0.10 300.00 $30.00 call back); email exchanges with client (A. Hirsh) re efforts to contact realtor; 05-24-21 KJL Teleconference with client (A. Hirsh) re status and further handling; 0.10 300.00 $30.00 06-10-21 KJL Conference with SRW regarding subpoenas and further efforts to obtain 0.10 300.00 $30.00 compliance; 06-11-21 SW Follow up with third party witnesses on failure to respond to subpoenas 0.70 250.00 $175.00 06-25-21 Locate potential phone number for Samantha Shea; attempt to contact 0.90 175.00 $157.50 Jackie Davis regarding subpoena 07-02-21 KJL Receive and review client email (A. Hirsh) re case status; 0.10 300.00 $30.00 Page: 5 07-06-21 KJL Correspondence with SRW re contact with client (A. Hirsh); 0.10 300.00 $30.00 07-07-21 KJL Teleconference with client (A. Hirsh) regarding case status; confer with 0.50 300.00 $150.00 SRW re further case handling; communicate with realtor (J. Davis) re overdue subpoena response; communicate with buyer's counsel (K. Costello) re overdue subpoena response from clients; 07-07-21 SW Review land records in connection with contacting buyers to obtain 0.20 250.00 $50.00 documentation of sale of 121 Alden 07-08-21 KJL Email exchanges with home buyer and their counsel re subpoena; email 0.20 300.00 $60.00 exchanges with SRW re same; email to clients re same; 07-09-21 KJL Conference with SRW regarding Certificate of Closed Pleadings and 0.20 300.00 $60.00 follow up on subpoenas; follow up email to realtor (J. Davis) (cc: clients / SRW) regarding subpoena compliance; email exchanges with client (A. Hirsh / L. Lind) (cc: SRW) regarding subpoenas and case status / further handling; 07-09-21 SW Speak with buyer's attorney in connection with obtaining responses from 0.50 250.00 $125.00 them; file certificate of closed pleadings; contact caseflow regarding trial date 07-10-21 KJL Receive and review email reply from realtor (J. Davis) regarding 0.10 300.00 $30.00 subpoena; 07-12-21 KJL Teleconference with client (A. Hirsh) re Jackie Davis; email to Jackie 0.10 300.00 $30.00 Davis; 07-13-21 KJL Receive and review SRW email addressing ability to seek and recover 0.10 300.00 $30.00 punitive damages and amending Complaint; 07-13-21 SW Research permissability of recovering punitive damages 0.60 250.00 $150.00 07-14-21 KJL Conference with SRW regarding further case handling including 0.40 300.00 $120.00 outstanding subpoenas and amendment of pleading email to realtor (J. Davis) re subpoena response; email exchanges with client (A. Hirsh) re status and recommended further handling to amend complaint ; 07-15-21 KJL Email exchanges with realtor (J. Davis) regarding subpoena compliance; 0.30 300.00 $90.00 telecom with J. Davis; email exchanges with client (A. Hirsh) (cc: SRW) regaridng dealings with Jackie Davis; 07-19-21 KJL Conference with SRW regarding further handling of subpoenas and 0.20 300.00 $60.00 litigation; email exchanges with client (A. Hirsh) re strategy to amend Complaint and put pressure on Gold; 07-22-21 SW Research standard for leave to amend complaint upon presentation of 1.80 250.00 $450.00 new information in connection with drafting same; draft motion for leave to amend 07-22-21 SW Research causes of action 1.30 250.00 $325.00 07-22-21 SW Continue drafting motion for leave to amend 0.50 250.00 $125.00 Page: 6 07-22-21 SW Speak with attorney for purchasers in connection with obtaining 0.20 250.00 $50.00 responsive information to subpoena 07-26-21 SW Contact Debit Moris from attorney for buyer regarding production of file 0.10 250.00 $25.00 07-26-21 KJL Email received from client (A. Hirsh) re status and further efforts; receive 0.10 300.00 $30.00 and review status update on drafting status from SRW; 07-28-21 KJL Email to client (A. Hirsh) re status of motion to amend Complaint; email 0.10 300.00 $30.00 exchanges with SRW re same; 07-30-21 SW Research and review case law on motion for leave to amend standard in 0.60 250.00 $150.00 connection with drafting same. 07-30-21 SW Continue drafting motion for leave to amend complaint 1.00 250.00 $250.00 07-30-21 SW Research elements of newly discovered causes of action and draft 1.60 250.00 $400.00 amended complaint to include same 08-03-21 KJL Email exchanges with client (A. Hirsh) (cc: SRW) re status of motion to 0.10 300.00 $30.00 amend complaint; 08-10-21 KJL Review of draft motion to amend Complaint and amended Complaint; 0.50 300.00 $150.00 return drafts to SRW with edits for finalization and filing; receive and review SRW email to opposing counsel (H. Hirsch) forwarding motion papers; 08-10-21 SW Finalize and file request for leave to amend and proposed amended 0.40 250.00 $100.00 complaint 08-12-21 SW Correspond with clients regarding case update re Motion for Leave to 0.10 250.00 $25.00 Amend 08-12-21 KJL Receive and review email communications by SRW and client (A. Hirsh) 0.10 300.00 $30.00 regarding case status and next steps; 08-13-21 KJL Email to client (A. Hirsh) regarding case status and expected further case 0.10 300.00 $30.00 developments / timetable; 08-24-21 KJL Receive and review defendant's objection to motion to amend complaint; 0.20 300.00 $60.00 09-01-21 KJL Conference with SRW regarding court hearing on motion to amend 0.10 300.00 $30.00 complaint and further handling; 09-02-21 KJL Review of defendant's objection to motion for leave to file amended 0.30 300.00 $90.00 complaint; email exchanges with SRW regarding reply to objection and handling of court hearing; email exchanges with client (A. Hirsh) (cc: SRW) re case status and further handling; 09-03-21 KJL Review of draft reply to defendant's opposition to motion to amend 0.30 300.00 $90.00 complaint; email exchanges with SRW re same; 09-03-21 SW Draft reply to objection to leave to amend; 0.90 250.00 $225.00 Page: 7 09-07-21 SW Finalize and file reply to objection to motion for leave to amend; 0.30 250.00 $75.00 09-08-21 SW Preapre for hearing on motion for leave to amend; attend hearing on 0.50 250.00 $125.00 motion for leave to amend; 09-08-21 KJL Conference with SRW regarding today's hearing and mediation and 0.10 300.00 $30.00 further handling; 09-09-21 KJL Receive and review SRW email to defense counsel (H. Hirsh) regarding 0.10 300.00 $30.00 recent filing; receive and review defendant's requests to admit; save to file; 09-15-21 KJL Email to clients (A. Hirsh / L. Lind) forwarding request for admissions for 0.40 285.00 $114.00 review and comment; calendar reply deadline; receive SRW email advising on next week's mediation / hearing; telecom with client (A. Hirsh) re mediation and pending motion; discuss further handling with SRW; 09-20-21 KJL Conference with SRW regarding position for mediation; confer with SRW 0.20 300.00 $60.00 regarding outcome of hearing on motion to amend and further case handling; 09-20-21 SW Call with Alan Hirsh in advance of hearing 0.10 250.00 $25.00 09-20-21 SW Attend at hearing on motion for leave to amend; 0.40 250.00 $100.00 09-20-21 SW Prepare for hearing on motion for leave to amend; 0.70 250.00 $175.00 09-24-21 KJL Email to clients (A. Hirsh / L. Lind) requesting comments on requests to 0.10 300.00 $30.00 admit; 09-27-21 KJL Email exchanges with clients (A. Hirsh / L. Lind) regarding requested 0.20 300.00 $60.00 admissions; confer with SRW regarding Amended Complaint; receive and review email to defendant's counsel serving Amended Complaint; 09-27-21 SW Finalize and file amended complaint; correspond with counsel for 0.20 250.00 $50.00 defendant regarding same; 09-28-21 KJL Email exchanges with clients (L. Lind / A. Hirsh) (cc: SRW) regarding 0.10 300.00 $30.00 Monday meeting to review defendant's requested admissions; diary meeting in calendar; 10-04-21 KJL Draft responses to requests for admission; meet with clients (L. Lind / A. 1.20 300.00 $360.00 Hirsh) and SRW to review defendant's requested admissions; emails exchanged with client (L. Lind) ; revising responses to requested admissions; emails exchanged with SRW re responses; 10-05-21 KJL Conference with SRW regarding admissions; email to clients (L. Lind / A. 0.10 300.00 $30.00 Hirsh) (cc: SRW) ; 10-06-21 KJL Email exchanges with clients (L. Lind / A. Hirsh) and SRW 0.10 300.00 $30.00 ; 10-07-21 KJL DISCOVERY - execute Verification pages and send to SRW; communicate 0.10 300.00 $30.00 with SRW regarding discovery; Page: 8 10-07-21 SW Finalize responses to Request to Admit and file same; communicate with 0.40 250.00 $100.00 defense counsel regarding responses to request to admit; draft notice of response to requests to admit and file same with court; 10-08-21 SW Finalize and file notice of response to request to admit; communicate 0.20 250.00 $50.00 with counsel for defendant regarding requests to admit; 10-08-21 SW Review pleadings, documents, and correspondence in connection with 1.60 250.00 $400.00 drafting discovery requests; draft discovery requests; 10-11-21 SW Review practice book and statutory requirements for pleading to an 0.20 250.00 $50.00 amended complaint in connection with ascertaining appropriate response to Defendant's answer, special defenses, and counterclaim; 10-13-21 KJL Receive and review Defendant's Answer to Amended Complaint with 0.30 300.00 $90.00 Special Defenses and Counterclaim; save to file; email to Gold counsel (H. Hirsh); email exchanges and conferring with SRW re next steps; email exchange with clients (H. Hirsh / L. Lind) forwarding Gold's Answer to Amended Complaint with Counterclaim and addressing next steps; 10-21-21 KJL Receive and review client inquiry (A. Hirsh) restatus; 0.10 300.00 $30.00 10-23-21 KJL Email to SRW requesting update on discovery status for client update; 0.10 300.00 $30.00 10-25-21 KJL Correspondence with SRW regarding discovery, request to revise and 0.10 285.00 $28.50 update to client; 10-25-21 SW Review Amended Answer and Special Defenses in connection with 2.00 250.00 $500.00 drafting responsive pleading to same; draft response to amended answer and special defenses and counterclaim; draft updated discovery requests to be served on Lisa Gold; 10-27-21 KJL Review of Request to Revise; communicate wiith SRW re same; 0.10 300.00 $30.00 10-27-21 SW Draft request to revise amended answer and counterclaim; 1.00 250.00 $250.00 10-28-21 KJL Receive and review service of request to revise on Gold's counsel; 0.10 300.00 $30.00 10-28-21 SW Revise request to revise, finalize and file same; correspond with Harry 0.30 250.00 $75.00 Hirsch regarding service of same; 10-29-21 KJL Email exchanged with clients (A. Hirsh / L. Lind) re status update - 0.10 300.00 $30.00 request to revise served on Gold's counsel and discovery to be propounded; 11-03-21 KJL Email received from SRW with draft discovery requests; 0.10 300.00 $30.00 11-07-21 SW Finalize and serve discovery requests on Lisa Gold; file notice of service 0.40 250.00 $100.00 with the court; correspond with attorney for Lisa Gold regarding same; 11-08-21 KJL Email exchanges with client (A. Hirsh) re case status; email exchanges 0.10 300.00 $30.00 with SRW re same; 11-29-21 KJL Receive and review defendant's responses and objection to request to 0.20 300.00 $60.00 revise; receive and review invite for hearing on request to revise; email received from client (A. Hirsh) re same; Page: 9 12-13-21 KJL Email received from client (A. Hirsh) re upcoming hearing; 0.10 300.00 $30.00 12-14-21 KJL Receive and review SRW communications with client (A. Hirsh) re 0.10 300.00 $30.00 tomorrow's hearing; briefly confer with SRW re hearing coverage; 12-15-21 KJL Conference with SRW re hearing outcome on request to revise and next 0.20 300.00 $60.00 steps in case; receive and review SRW email exchanges with client (A. Hirsh / L. Lind) re status and next steps; 12-15-21 SW Attend at hearing on request to revise; draft e-mail to Laura and Alan 0.50 250.00 $125.00 regarding outcome of hearing and next steps; 12-15-21 SW Prepare for hearing on request to revise; 0.50 250.00 $125.00 12-24-21 KJL Receive and review landlord's discovery responses; email exchanges 0.10 300.00 $30.00 with SRW re discovery responses and objections; 12-27-21 KJL Receive and review landlord's revised Answer, Special Defenses and 0.10 300.00 $30.00 Counterclaim and objections to discovery; 12-30-21 KJL Correspondence with SRW regarding further case handling - response to 0.10 300.00 $30.00 Counterclaim, resolving landlord's objections to discovery and propounding additional discovery on alleged counterclaims; 01-05-22 KJL Email received from client (A. Hirsh) re status; 0.10 300.00 $30.00 01-06-22 KJL Email exchanges with client (A. Hirsh / L. Lind) (cc: SRW) regarding case 0.20 300.00 $60.00 status, trial date, etc.; 01-11-22 KJL Receive and review SRW emails with clients (A. Hirsh / L. Lind) re review 0.10 300.00 $30.00 of discovery responses; 01-11-22 SW Correspond with Laura and Alan regarding discovery responses; 0.10 250.00 $25.00 01-11-22 SW Speak with Alan regarding discovery responses and next steps in 0.20 250.00 $50.00 pushing matter towards resolution; 01-11-22 SW Review discovery requests from Lisa Gold; Draft objections to discovery 1.40 250.00 $350.00 requests; draft initial responses to discovery requests; 01-14-22 SW Meet with Laura and Alan regarding answers to discovery requests; 0.50 250.00 $125.00 01-14-22 KAB Notarize Plaintiff's Certification 0.10 90.00 $9.00 02-16-22 SW Review correspondence from Harry Hirsh regarding revised answer and 0.10 250.00 $25.00 special defenses; 02-16-22 SW Finalize and file Objections to Discovery requests; finalize and sent 0.80 250.00 $200.00 responses to discovery requests to attorney for Lisa Gold; Correspond with Harry Hirsch regarding same 02-17-22 KJL Receive and review Court invite for remote hearing on Order for 0.10 300.00 $30.00 Compliance; receive email from client (A. Hirsh) re same; Page: 10 02-23-22 SW Correspond with Alan Hirsh and Laura Lind regarding scheduled 0.10 250.00 $25.00 mediation hearing; 03-17-22 SW Review revised answer, special defense, and counterclaim filed by Lisa 1.20 250.00 $300.00 Gold in connection with determining compliance of same with court ordered revisions; draft responsive pleading to revised answer, special defense, and counterclaim; 03-25-22 KJL Receive and review SRW email exchanges with client (A. Hirsh) re case 0.10 300.00 $30.00 status; receive and review SRW email exchanges with opposing counsel (H. Hirsch) re Monday's court conference; receive and review continuance file by SRW; 03-25-22 SW Correspond with Alan regarding status of matter; draft motion to 0.40 250.00 $100.00 continue March 28, 2022 hearing pending resolution of discovery disputes; correspond with Harry Hirsch regarding motion filed with Court; 03-25-22 SW Correspond with Harry Hirsch regarding upcoming hearing and 0.10 250.00 $25.00 discussion of outstanding discovery disputes; 03-25-22 SW Contact court regarding motion for continuance; 0.10 250.00 $25.00 03-28-22 SW Attend at hearing on motion to compel; 0.20 250.00 $50.00 03-28-22 SW Review responses to discovery request in preparation for hearing on 0.20 250.00 $50.00 discovery dispute; 04-05-22 SW Engage in good faith discovery resolution with Harry Hirsch; 0.50 250.00 $125.00 04-05-22 SW Review discovery disputes in advance of good faith discussion with 0.50 250.00 $125.00 Harry Hirsch regarding same; 05-18-22 KJL Receive and review client email (A. Hirsh) re case status; 0.10 300.00 $30.00 05-19-22 KJL Receive and review SRW case update to client (A. Hirsh); receive and 0.20 300.00 $60.00 review SRW email to landlord's counsel (A. Hirsh) re discovery issues; 05-19-22 SW Correspond with Alan and Linda regarding status of case; review status 1.30 250.00 $325.00 of pleadings and correspondence with Harry Hirsch in connection with obtaining discovery compliance from Lisa Gold; Draft corrspondence with Harry Hirsch regarding outstanding discovery compliance; 06-14-22 SW Correspond with Harry Hirsch regarding outstanding production; 0.10 250.00 $25.00 06-21-22 SW Contact Harry Hirsch regarding status conference with Court for June 22, 0.10 250.00 $25.00 2022; 06-21-22 SW Correspond with clerk of court regarding status conference scheduled 0.10 250.00 $25.00 fo4 6/22/2022; 06-22-22 KJL Receive and review disclosures from landlord re party communications; 0.10 300.00 $30.00 06-27-22 KJL Email exchanges with SRW regarding review of landlord's disclosures 0.10 300.00 $30.00 and further case handling; Page: 11 06-28-22 KJL Receive court notice for Trial Order; conferring with SRW re further case 0.10 300.00 $30.00 handling; 06-29-22 SW Correspond with Alan Hirsh regarding status of the matter; 0.10 250.00 $25.00 07-01-22 KJL Receive and review SRW email to opposing counsel (H. Hirsch) re trial 0.20 300.00 $60.00 scheduled by court; communicate with SRW re further case handling; review motion for continuance of trial; 07-05-22 SW Review production from Harry Hirsch, attorney for Lisa Gold, in 0.70 250.00 $175.00 connection with determining relevance and compliance with production requests; correspond with Alan Hirsh and Laura Lind 07-05-22 KJL Review email exchanges by SRW and defense counsel re defendant's 0.20 300.00 $60.00 disclosures; review SRW communications with clients (A. Hirsh / L. Lind) re case status and trial; 07-07-22 KJL Receive defense counsel email re further efforts with client to disclose all 0.10 300.00 $30.00 documentation; 07-20-22 KJL Receive and review defendant's motion to allow witnesses to appear for 0.10 300.00 $30.00 trial via remote means; 07-21-22 SW Correspond with Laura Lind and Alan Hirsh regarding upcoming hearing; 0.10 250.00 $25.00 07-21-22 KJL Review SRW emails with clients regarding hearing / trial on August 3 and 0.20 300.00 $60.00 preparation session; review caseflow request filed by defense counsel requesting remote hearing attendance; 07-22-22 KJL Review SRW email exchanges with clients (A. Hirsh / L. Lind) re trial 0.10 300.00 $30.00 preparation; 07-25-22 KJL Confer with SRW regarding defendant's motion to allow witness to 0.70 300.00 $210.00 remotely testify and trial preparation; 07-26-22 KJL Edit direct and cross-examinations drafted by SRW; meet with clients (A. 3.00 300.00 $900.00 Hirsh / L. Lind) and SRW in preparation for trial next week; receive and review defendant's trial brief; discuss with SRW; reviewing claim documents / evidence and caselaw; 07-26-22 SW Prepare direct examination of Laura Lind, Alan Hirsh, and cross 3.00 250.00 $750.00 examination of Lisa Gold in preparation for trial on August 3, 2020; 07-26-22 SW Meet with Laura Lind and Alan Hirsh regarding preparation for trial on 1.50 250.00 $375.00 August 3, 2022; 07-26-22 SW Review Trial Management Report filed by Harry Hirsch, counsel for 1.00 250.00 $250.00 Defendant, in preparation for pre-trial conference on July 27, 2022; develop trial strategy with KJL; 07-27-22 KJL Draft Plaintiffs' Trial Brief; conferring with SRW; editing / revising 2.50 300.00 $750.00 Plaintiffs' Trial Brief; attend at remote pre-trial hearing with SRW; confer with SRW following hearing; researching ; review SRW communications with clients (A. Hirsh / L. Lind) re trial; receive defendant's amended witness list; Page: 12 07-27-22 SW Revise Trial Management report in advance of submitting same to Court; 0.50 250.00 $125.00 07-27-22 SW Finalize and file Pre-Trial Memorandum in advance of hearing; 0.20 250.00 $50.00 07-27-22 SW Speak with ; 0.20 250.00 $50.00 07-27-22 SW Attend at pre-trial conference; 0.50 250.00 $125.00 07-29-22 SW Review correspondence with Harry Hirsch regarding request for 1.50 250.00 $375.00 continuance; review motion for continuance filed by Harry Hirsch; review practice book regarding basis for continuance; draft objection to motion for continuance; 07-29-22 KJL Receive defense counsel (H. Hirsh) request for adjournment based on 1.50 300.00 $450.00 alleged unavailability of witness; confer with SRW; communication with H. Hirsh regarding adjournment request; researching ; researching review / research CT Practice Book sections on requested trial adjournments; review and edit draft Objection; review Court Order granting continuance; conferring with SRW; review ; 08-01-22 KJL Communicate with SRW and clients (A. Hirsh / L. Lind) re new trial date; 0.20 300.00 $60.00 diary trial date in calendar; review ; confer with SRW re further case handling / trial preparation; 08-01-22 SW Review court calendar in connection with determining new trial date; 0.20 250.00 $50.00 correspond with Alan and Laura regarding new trial date; correspond with ; 08-03-22 KJL Email exchanges with clients (A. Hirsh / L. Lind) re moving trial date to 0.20 300.00 $60.00 October; email to ; 08-08-22 KJL Email to defense counsel (H. Hirsch / A. Hirsch) (cc: SRW) seeking 0.10 300.00 $30.00 consent for trial continuance to middle of October; 08-09-22 KJL Email exchanges with defense counsel (H. Hirsch / A. Hirsch) (cc: SRW) 0.40 300.00 $120.00 re trial date adjustment; email exchanges with clients (A. Hirsh / L. Lind) (cc: SRW) re same; email exchanges ; discuss Lisa Gold apparent witness tampering with SRW; 08-10-22 KJL Email exchanges with clients (L. Lind / A. Hirsh) regarding adjournment 0.80 300.00 $240.00 of trial date and necessity to attend trial; draft and file continuance motion for new trial date; serve continuance motion on defense counsel (H. Hirsch / A. Hirsch); email exchanges ; email exchanges with SRW re follow up on subpoenas; confer with SRW re Laura Gold witness tampering and further case handling; receive receive Tancredi-Gold communications; research witness tampering in state of CT; 08-10-22 SW Correspond with ; 0.20 250.00 $50.00 08-11-22 SW Review 0.30 250.00 $75.00 08-11-22 KJL Discuss with SRW 0.10 300.00 $30.00 Page: 13 08-12-22 KJL Email exchanges with SRW re adjourned trial date; 0.10 300.00 $30.00 08-15-22 KJL Review SRW messages with clients (A. Hirsh / L. Lind) and non-party 0.20 300.00 $60.00 (Mark Tancredi) re new trial date; communicate with SRW ; 08-18-22 KJL Receive and review email ; 0.10 300.00 $30.00 08-23-22 KJL Email exchanges with SRW re , subpoena follow up and 0.20 300.00 $60.00 further case handling / strategy; communicate with SRW re further handling; 10-18-22 KJL Review file in preparation for upcoming trial; communicate with client (A. 0.30 300.00 $90.00 Hirsh / L. Lind) regarding case status, trial preparation, etc..; 10-19-22 KJL Receive updated witness list from defense counsel; email to defense 0.30 300.00 $90.00 counsel (H. Hirsh) advising Mark Tancredi will be called at trial and providing communications showing defendant tried to silence Tancredi from testifying; communicate with SRW re possible motion to preclude client's ex-husband from testifying at trial; 10-21-22 KJL Email exchanges with clients (A. Hirsh / L. Lind) (cc: SRW) regarding trial 0.10 300.00 $30.00 preparation meeting next week; 10-25-22 KJL Discuss case and upcoming trial with SRW; 0.20 300.00 $60.00 10-26-22 KJL Communicate with SRW re trial preparation; reviewing file; revising direct 1.50 300.00 $450.00 examinations for clients; meet with clients for trial preparation; email exchanges with SRW re Mark Tancredi; 10-26-22 SW ; 0.50 250.00 $125.00 research basis for motion for protective order to preclude David Fresne from testifying; contact States Attorney and Attorney Generals office regarding reporting misconduct of Lisa Gold with respect to witness tampering; renew preparation for trial; 10-26-22 SW Prepare for trial and meet with Laura Lind and Alan Hirsh; 2.00 250.00 $500.00 10-27-22 KJL Receive defendant's motion in limine to preclude Mark Tancredi; email 2.00 300.00 $600.00 exchanges with defense counsel (H. Hirsh) re same; discuss opposition with SRW and affirmative motion in limine to preclude David Fresne; drafting opposition to defendant's motion in limine; review SRW communications with Mark Tancredi; review / edit draft motion to preclude David Fresen; receive and review defendant's Caseflow Request re remote testimony of two witnesses; 10-27-22 SW Review amended trial witness list in connection with drafting motion to 2.60 250.00 $650.00 preclude; review correspondence between Laura Lind and Lisa Gold in connection with drafting motion to preclude; draft motion to preclude; 10-28-22 SW Correspond with ; 0.10 250.00 $25.00 10-28-22 KJL Email exchanges with SRW re ; review 0.20 300.00 $60.00 SRW communications ; review SRW communications with client (L. Lind) regarding David Fresne; receive email from defense counsel (H. Hirsch) regarding witnesses for remote testimony; review motion in limine filed to preclude testimony of David Fresne; Page: 14 10-28-22 SW Speak with 0.30 250.00 $75.00 draft subpoena for attendance of Mark Tancredi; 10-28-22 SW Finalize and file motion to preclude David Fresne; 0.70 250.00 $175.00 10-31-22 KJL Confer with SRW re trial preparation; email to defense counsel (H. Hirsh) 1.50 300.00 $450.00 regarding witnesses he seeks to be allowed to testify via remote means; reviewing file and revising direct exam for Laura Lind; drafting exam for Lisa Gold; organizing trial exhibits to be uploaded to court's system; reviewing file; 11-01-22 KJL Trial preparation - drafting / revising direct ex