Preview
FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022
NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024
Robert E. Bailey, Senior Deputy General Counsel
Brian M. Doyle, Associate Counsel
Santander Holdings USA, Inc.
45 East 53rd Street, 15th Floor
New York, NY 10022
File Number: 104673.000003
Please remit payment within 30 days from date of invoice
Santander Bank, N.A. Date: 12/12/22
RE: VativoRX Litigation Invoice: 886366
Client Ref: 2022-0002411
For Professional Services Rendered and Costs Advanced through 11/30/22
Date Atty Professional Services Hours
11/17/22 JB Review complaint and background through 1.00
telephone conferences and document review.
11/21/22 JB Review Redacted 2.20
Redacted through telephone conference and
document review.
11/23/22 JB Emails with counsel group regarding strategy. 0.30
11/25/22 JB Emails with client and counsel regarding strategy. 0.20
11/27/22 JB Suggest revisions to complaint. 0.80
11/28/22 JB Communications call with counsel regarding 1.00
strategy Redacted .
11/28/22 JB Further communications with counsel regarding 1.00
strategy Redacted .
11/30/22 JB Suggest further edits to complaint. 0.60
Total Hours 7.10
Total Current Fees $4,437.50
Current Invoice Due $4,437.50
FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022
NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024
Santander Bank, N.A. Client: 104673
November 30, 2022 Matter: 104673.000003
Page 2 Invoice: 886366
FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022
NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024
Robert E. Bailey, Senior Deputy General Counsel
Brian M. Doyle, Associate Counsel
Santander Holdings USA, Inc.
45 East 53rd Street, 15th Floor
New York, NY 10022
File Number: 104673.000003
Please remit payment within 30 days from date of invoice
Santander Bank, N.A. Date: 01/31/23
RE: VativoRX Litigation Invoice: 888414
Client Ref: 2022-0002411
For Professional Services Rendered and Costs Advanced through 12/31/22
Date Atty Professional Services Hours
12/02/22 JB Emails with counsel regarding status. 0.20
12/06/22 JB Emails with counsel regarding status. 0.10
12/06/22 JB Review revised draft complaint. 0.30
12/07/22 JB Emails with client and counsel regarding Redacted 0.20
Redacted.
Total Hours 0.80
Total Current Fees $500.00
Current Invoice Due $500.00
FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022
NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024
Robert E. Bailey, Senior Deputy General Counsel
Brian M. Doyle, Associate Counsel
Santander Holdings USA, Inc.
45 East 53rd Street, 15th Floor
New York, NY 10022
File Number: 104673.000003
Please remit payment within 30 days from date of invoice
Santander Bank, N.A. Date: 02/07/23
RE: VativoRX Litigation Invoice: 890484
Client Ref: 2022-0002411
For Professional Services Rendered and Costs Advanced through 01/31/23
Date Atty Professional Services Hours
01/23/23 JB Review motion papers. 0.80
01/23/23 JB Emails with counsel regarding strategy. 0.40
01/23/23 JB Review and revise letter to court. 0.20
01/27/23 JB Review opposition memorandum. 0.70
01/27/23 JB Emails with counsel regarding Redacted. 0.30
01/30/23 JB Emails with counsel regarding status. 0.20
01/31/23 JB Telephone conference with counsel regarding 0.70
status and strategy.
01/31/23 JB Email to client re status. 0.10
01/31/23 JB Review reply brief. 0.30
01/31/23 JB Review order on motion. 0.20
01/31/23 TLA Prepare Notice of Appearance for J. Brydges and 0.50
file same.
Total Hours 4.40
Total Current Fees $2,542.50
Current Invoice Due $2,542.50
FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022
NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024
Robert E. Bailey, Senior Deputy General Counsel
Brian M. Doyle, Associate Counsel
Santander Holdings USA, Inc.
45 East 53rd Street, 15th Floor
New York, NY 10022
File Number: 104673.000003
Please remit payment within 30 days from date of invoice
Santander Bank, N.A. Date: 03/21/23
RE: VativoRX Litigation Invoice: 894327
Client Ref: 2022-0002411
For Professional Services Rendered and Costs Advanced through 02/28/23
Date Atty Professional Services Hours
02/01/23 JB Review Court filings. 0.30
02/02/23 JB Telephone conference with J. Manning regarding 0.20
Redacted
02/02/23 JB Review court filings. 0.20
02/03/23 JB Represent client attending preliminary 0.80
conference.
02/03/23 JB Emails with counsel regarding Redacted 0.30
02/06/23 JB Emails with counsel regarding Redacted 0.30
Redacted .
02/06/23 JB Revise responsive pleading. 0.20
02/06/23 JB Review Redacted 0.30
Redacted .
02/06/23 JB Review application to AD. 0.40
02/07/23 JB Emails with counsel regarding status. 0.30
02/08/23 JB Emails with counsel regarding status and Redacted 0.60
Redacted .
02/08/23 JB Telephone conference with plaintiffs' counsel 0.10
regarding strategy.
02/08/23 JB Telephone conference with all counsel regarding 0.70
Redacted.
02/09/23 JB Emails with counsel regarding Redacted 0.30
Redacted .
02/10/23 JB Review and revise stipulation. 0.30
FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022
NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024
Santander Bank, N.A. Client: 104673
February 28, 2023 Matter: 104673.000003
Page 2 Invoice: 894327
Date Atty Professional Services Hours
02/10/23 JB Emails with counsel regarding status. 0.40
02/14/23 JB Review and revise answer to counterlcaims. 0.40
02/16/23 JB Emails with counsel regarding Redacted 0.20
Redacted.
02/17/23 JB Review opposition to motion to dismiss and 0.50
discovery demands.
02/22/23 JB Review final consent order. 0.20
Total Hours 7.00
Total Current Fees $4,375.00
Current Invoice Due $4,375.00
FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022
NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024
Robert E. Bailey, Senior Deputy General Counsel
Brian M. Doyle, Associate Counsel
Santander Holdings USA, Inc.
45 East 53rd Street, 15th Floor
New York, NY 10022
File Number: 104673.000003
Please remit payment within 30 days from date of invoice
Santander Bank, N.A. Date: 05/18/23
RE: VativoRX Litigation Invoice: 898021
Client Ref: 2022-0002411
For Professional Services Rendered and Costs Advanced through 04/30/23
Date Atty Professional Services Hours
04/05/23 CFK Telephone call with J. Brydges to discuss 2.00
Redacted ; review sample
Redacted
; review complaint; attend meet and confer
Redacted
Redacted
with plaintiffs and defendant; draft summary of
meet and confer.
04/06/23 CFK Review pleadings, motions, and discovery 1.50
responses to date Redacted
Redacted
Redacted .
04/12/23 JB Emails with plaintiffs' counsel regarding status. 0.20
04/12/23 JB Communication with client regarding status. 0.10
04/17/23 JB Review correspondence regarding discovery. 0.30
04/17/23 JB Review ediscovery protocol. 0.10
04/17/23 JB Emails with client regarding Redacted. 0.10
04/18/23 JB Telephone conference with client regarding 0.20
Redacted .
04/18/23 JB Review third party subpoenas. 0.30
04/19/23 JB Emails among team and client regarding 0.30
Redacted.
04/19/23 TLA Discuss Redacted with J. 0.40
Brydges: communicate with I. Antinoro regarding
Redacted .
FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022
NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024
Santander Bank, N.A. Client: 104673
April 30, 2023 Matter: 104673.000003
Page 2 Invoice: 898021
Date Atty Professional Services Hours
04/20/23 JB Emails with counsel regarding Redacted. 0.30
04/20/23 JB Emails with client regarding Redacted. 0.20
04/20/23 JB Emails with counsel regarding Redacted. 0.20
04/27/23 JB Review Redacted . 0.20
Total Hours 6.40
Total Current Fees $2,959.00
Current Invoice Due $2,959.00
FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022
NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024
Robert E. Bailey, Senior Deputy General Counsel
Brian M. Doyle, Associate Counsel
Santander Holdings USA, Inc.
45 East 53rd Street, 15th Floor
New York, NY 10022
File Number: 104673.000003
Please remit payment within 30 days from date of invoice
Santander Bank, N.A. Date: 05/18/23
RE: VativoRX Litigation Invoice: 899440
Client Ref: 2022-0002411
For Professional Services Rendered and Costs Advanced through 03/31/23
Date Atty Professional Services Hours
03/06/23 JB Emails with team regarding Redacted, review 0.70
appellate filings/review reply brief.
03/07/23 JB Telephone conference with Counsel group 0.30
regarding Redacted.
03/09/23 JB Review correspondence to borrower’s counsel. 0.20
03/10/23 JB Telephone conference with client regarding 0.20
Redacted, review interrogatory responses.
03/13/23 JB Review correspondence from borrower’s counsel. 0.20
03/16/23 JB Emails with counsel regarding Redacted 0.20
Redacted .
03/16/23 JB Emails with client re Redacted . 0.10
Redacted
03/16/23 JB Review discovery responses. 0.30
03/17/23 JB Review interrogatory responses and revise same, 0.70
emails with J . Manning regarding Redacted.
03/20/23 JB Emails with counsel regarding Redacted 0.20
Redacted .
Total Hours 3.10
Total Current Fees $1,937.50
FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022
NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024
Santander Bank, N.A. Client: 104673
March 31, 2023 Matter: 104673.000003
Page 2 Invoice: 899440
Current Invoice Due $1,937.50
FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022
NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024
Robert E. Bailey, Senior Deputy General Counsel
Brian M. Doyle, Associate Counsel
Santander Holdings USA, Inc.
45 East 53rd Street, 15th Floor
New York, NY 10022
File Number: 104673.000003
Please remit payment within 30 days from date of invoice
Santander Bank, N.A. Date: 06/12/23
RE: VativoRX Litigation Invoice: 901155
Client Ref: 2022-0002411
For Professional Services Rendered and Costs Advanced through 05/31/23
Date Atty Professional Services Hours
05/02/23 JB Emails with client regarding Redacted . 0.20
05/02/23 JB Emails with counsel regarding Redacted. 0.30
05/03/23 JB Emails with counsel regarding Redacted 0.30
Redacted.
05/04/23 JB Emails with counsel regarding Redacted 0.20
Redacted.
05/05/23 JB Emails with plaintiffs group regarding Redacted 0.20
Redacted
.
05/05/23 JB Draft Redacted . 0.60
05/08/23 JB Review subpoenas. 0.40
05/09/23 JB Emails with counsel regarding Redacted . 0.50
05/10/23 JB Emails with plaintiff group regarding Redacted 0.20
Redacted .
05/11/23 JB Emails with counsel regarding Redacted . 0.30
Redacted
05/15/23 JB Emails with plaintiffs’ counsel regarding Redacted 0.30
Redacted
.
05/16/23 JB Emails with group regarding Redacted . 0.20
Redacted
05/18/23 JB Emails with group regarding Redacted 0.20
Redacted.
05/18/23 JB Review confidentiality stipulation and order. 0.20
05/18/23 JB Emails with I. Antinoro regarding Redacted 0.20
Redacted.
05/19/23 JB Begin review of client documents for production. 3.80
FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022
NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024
Santander Bank, N.A. Client: 104673
May 31, 2023 Matter: 104673.000003
Page 2 Invoice: 901155
Date Atty Professional Services Hours
05/22/23 JB Emails with counsel regarding Redacted. 0.30
05/22/23 JB Review client documents. 4.50
05/22/23 JB Emails with counsel regarding discovery. 0.20
05/23/23 JB Continue document review for production. 5.30
05/23/23 JB Telephone conference with client regarding 0.20
Redacted .
05/24/23 JB Continue document review. 4.50
05/25/23 JB Continue document review. 2.30
05/26/23 JB Continue document review. 2.50
05/30/23 JB Continue reviewing documents for production. 6.50
05/31/23 JB Continue document review. 3.80
05/31/23 JB Emails with counsel regarding Redacted . 0.30
Total Hours 38.50
Total Current Fees $24,062.50
Current Invoice Due $24,062.50
FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022
NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024
Robert E. Bailey, Senior Deputy General Counsel
Brian M. Doyle, Associate Counsel
Santander Holdings USA, Inc.
45 East 53rd Street, 15th Floor
New York, NY 10022
File Number: 104673.000003
Please remit payment within 30 days from date of invoice
Santander Bank, N.A. Date: 07/18/23
RE: VativoRX Litigation Invoice: 903658
Client Ref: 2022-0002411
For Professional Services Rendered and Costs Advanced through 06/30/23
Date Atty Professional Services Hours
06/01/23 JB Meeting with K. Berry regarding document 0.20
production.
06/01/23 JB Continue document review. 2.00
06/02/23 JB Continue document review. 1.20
06/05/23 JB Telephone conference with J. Manning regarding 0.20
Redacted .
06/06/23 JB Emails with counsel regarding Redacted 0.30
Redacted.
06/06/23 JB Emails with counsel regarding Redacted. 0.30
06/07/23 JB Review privileged documents and create privilege 2.00
log.
06/07/23 JB Emails with client Redacted . 0.20
Redacted
06/09/23 JB Redact documents for privilege and relevance. 5.50
06/12/23 JB Telephone conference with plaintiffs' counsel 0.60
regarding Redacted .
06/12/23 JB Review confidentiality designations. 2.00
06/13/23 JB Continue review of confidentiality designations. 2.20
06/14/23 JB Continue confidentiality review. 1.70
06/14/23 JB Emails with counsel regarding Redacted . 0.20
Redacted
06/16/23 JB Emails with counsel regarding Redacted. 0.20
06/19/23 JB Continue reviewing documents for redaction. 1.80
06/28/23 JB Review new batch of documents for production. 2.00
06/29/23 JB Finalize document production. 2.30
FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022
NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024
Santander Bank, N.A. Client: 104673
June 30, 2023 Matter: 104673.000003
Page 2 Invoice: 903658
Date Atty Professional Services Hours
06/29/23 JB Emails with K. Berry re document production. 0.20
Total Hours 25.10
Total Current Fees $15,687.50
Current Invoice Due $15,687.50
FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022
NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024
Robert E. Bailey, Senior Deputy General Counsel
Brian M. Doyle, Associate Counsel
Santander Holdings USA, Inc.
45 East 53rd Street, 15th Floor
New York, NY 10022
File Number: 104673.000003
Please remit payment within 30 days from date of invoice
Santander Bank, N.A. Date: 08/10/23
RE: VativoRX Litigation Invoice: 906202
Client Ref: 2022-0002411
For Professional Services Rendered and Costs Advanced through 07/31/23
Date Atty Professional Services Hours
07/07/23 JB Review and revise privilege logs. 1.00
07/10/23 JB Draft privilege logs. 2.30
07/11/23 JB Continue drafting privilege logs. 2.80
07/11/23 JB Emails with counsel regarding status and Redacted 0.50
.
Redacted
07/12/23 JB Finalize and serve privilege logs. 2.00
07/12/23 JB Emails with team regarding Redacted . 0.30
07/12/23 JB Review co-plaintiff logs. 0.60
07/12/23 JB Review reply brief on motion to enforce. 0.30
07/14/23 JB Review plaintiff's privilege logs. 0.50
07/18/23 JB Review papers on motion to enforce. 0.50
07/21/23 JB Review defendant status letter. 0.20
07/24/23 JB Review plaintiff's response regarding status on 0.20
motion to enforce.
07/26/23 JB Emails with counsel regarding Redacted and 0.30
strategy.
Total Hours 11.50
Total Current Fees $7,187.50
FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022
NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024
Santander Bank, N.A. Client: 104673
July 31, 2023 Matter: 104673.000003
Page 2 Invoice: 906202
Current Invoice Due $7,187.50
FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022
NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024
Robert E. Bailey, Senior Deputy General Counsel
Brian M. Doyle, Associate Counsel
Santander Holdings USA, Inc.
45 East 53rd Street, 15th Floor
New York, NY 10022
File Number: 104673.000003
Please remit payment within 30 days from date of invoice
Santander Bank, N.A. Date: 09/18/23
RE: VativoRX Litigation Invoice: 908886
Client Ref: 2022-0002411
For Professional Services Rendered and Costs Advanced through 08/31/23
Date Atty Professional Services Hours
08/03/23 JB Review summary judgment motion and deficiency 1.00
letter.
08/14/23 JB Review and revise pre-motion letter. 0.30
08/25/23 JB Emails with counsel regarding Redacted . 0.20
08/30/23 JB Telephone conference with team regarding 0.80
strategy.
08/30/23 JB Review Heffron deposition. 0.80
08/30/23 JB Review defendants' summary judgment motion. 1.20
08/31/23 JB Review and revise opposition brief. 0.50
08/31/23 JB Review Heffron deposition. 0.80
08/31/23 JB Emails with team regarding Redacted . 0.20
Total Hours 5.80
Total Current Fees $3,625.00
Current Invoice Due $3,625.00
FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022
NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024
Robert E. Bailey, Senior Deputy General Counsel
Brian M. Doyle, Associate Counsel
Santander Holdings USA, Inc.
45 East 53rd Street, 15th Floor
New York, NY 10022
File Number: 104673.000003
Please remit payment within 30 days from date of invoice
Santander Bank, N.A. Date: 10/23/23
RE: VativoRX Litigation Invoice: 912309
Client Ref: 2022-0002411
For Professional Services Rendered and Costs Advanced through 09/30/23
Date Atty Professional Services Hours
09/05/23 JB Emails with client regarding status. 0.20
09/05/23 JB Emails with counsel regarding Redacted. 0.20
09/06/23 JB Emails with counsel regarding Redacted . 0.20
09/06/23 JB Review reply brief draft. 0.50
09/11/23 JB Review Heffron transcript. 0.80
09/12/23 JB Review deposition notice topics. 0.30
09/12/23 JB Emails with counsel regarding Redacted. 0.20
09/13/23 JB Review deposition topics. 0.20
09/13/23 JB Emails with counsel regarding Redacted . 0.20
09/13/23 JB Telephone conference with counsel regarding 0.50
Redacted .
09/14/23 JB Emails with counsel regarding Redacted . 0.20
09/18/23 JB Emails w/ counsel re Redacted . 0.20
09/19/23 JB Emails with counsel and client regarding 0.70
Redacted .
09/20/23 JB Emails with counsel regarding Redacted . 0.30
09/20/23 JB Conference call with counsel group regarding 0.40
Redacted .
09/20/23 JB Review documents for Vativo deposition. 0.80
09/20/23 JB Review Santander production in advance of 1.60
30(b)(6) deposition.
09/21/23 JB Telephone conference with client regarding 0.20
Redacted .
FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022
NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024
Santander Bank, N.A. Client: 104673
September 30, 2023 Matter: 104673.000003
Page 2 Invoice: 912309
Date Atty Professional Services Hours
09/21/23 JB Review documents to prepare for deposition. 3.00
09/21/23 JB Meet and confer with Vativo counsel regarding 1.00
depositions.
09/22/23 JB Continue document review in preparation for 1.30
deposition.
09/22/23 JB Review revised deposition notice. 0.20
09/22/23 JB Emails with group regarding Redacted . 0.30
09/25/23 JB Continue review of documents in preparation for 2.80
deposition.
09/25/23 JB Emails with counsel regarding Redacted . 0.30
09/26/23 JB Emails with plaintiffs' counsel regarding 0.50
Redacted .
09/26/23 JB Review documents for depositions. 2.60
09/27/23 JB Emails with plaintiffs’ counsel regarding Redacted 0.30
Redacted .
Total Hours 20.00
Total Current Fees $12,500.00
Current Invoice Due $12,500.00
FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022
NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024
Robert E. Bailey, Senior Deputy General Counsel
Brian M. Doyle, Associate Counsel
Santander Holdings USA, Inc.
45 East 53rd Street, 15th Floor
New York, NY 10022
File Number: 104673.000003
Please remit payment within 30 days from date of invoice
Santander Bank, N.A. Date: 11/03/23
RE: VativoRX Litigation Invoice: 912741
Client Ref: 2022-0002411
For Professional Services Rendered and Costs Advanced through 10/31/23
Date Atty Professional Services Hours
10/05/23 JB Emails with counsel regarding status. 0.20
10/06/23 JB Emails with counsel regarding Redacted . 0.20
10/09/23 JB Telephone conference with plaintiffs' group 0.80
regarding Redacted .
10/12/23 JB Emails with counsel regarding Redacted . 0.20
10/12/23 JB Emails with client regarding Redacted . 0.10
10/13/23 JB Telephone conference with J. Manning regarding 0.20
Redacted .
10/16/23 JB Telephone conference with Plaintiffs’ counsel 0.50
regarding Redacted .
10/19/23 JB Emails with plaintiffs’ counsel regarding 0.30
Redacted .
10/23/23 JB Emails with counsel re Redacted . 0.30
10/24/23 JB Emails with counsel re Redacted . 0.20
10/24/23 JB Review revised deposition topics. 0.20
10/25/23 JB Telephone conference with bank counsel re 1.00
Redacted .
Total Hours 4.20
Total Current Fees $2,625.00
FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022
NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024
Santander Bank, N.A. Client: 104673
October 31, 2023 Matter: 104673.000003
Page 2 Invoice: 912741
Current Invoice Due $2,625.00
FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022
NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024
Robert E. Bailey, Senior Deputy General Counsel
Brian M. Doyle, Associate Counsel
Santander Holdings USA, Inc.
45 East 53rd Street, 15th Floor
New York, NY 10022
File Number: 104673.000003
Please remit payment within 30 days from date of invoice
Santander Bank, N.A. Date: 12/12/23
RE: VativoRX Litigation Invoice: 916011
Client Ref: 2022-0002411
For Professional Services Rendered and Costs Advanced through 11/30/23
Date Atty Professional Services Hours
11/01/23 JB Emails with counsel regarding Redacted 0.20
Redacted.
11/06/23 JB Emails with counsel regarding Redacted 0.30
Redacted.
11/07/23 JB Emails with counsel regarding Redacted. 0.30
11/09/23 JB Emails with counsel regarding Redacted . 0.30
11/13/23 JB Review transcript of argument. 1.00
11/15/23 JB Emails with counsel regarding Redacted . 0.30
11/17/23 JB Emails with counsel regarding Redacted 0.30
Redacted.
11/20/23 JB Continue document review in preparation for 2.00
Millman deposition.
11/20/23 JB T/c with J. Manning regarding Redacted . 0.30
11/21/23 JB Emails with client regarding Redacted . 0.30
11/27/23 JB Review Regions documents for depositions. 1.00
11/27/23 JB Prepare outline for Redacted . 2.00
11/27/23 JB Telephone conference with J. Manning regarding 1.00
Redacted .
11/27/23 JB Emails with B. Emmons regarding Redacted . 0.30
11/28/23 JB Prepare for meeting with J. Millman 1.50
11/28/23 JB Telephone conference with J. Millman and B. 1.00
Emmons regarding Redacted .
11/28/23 JB Review additional production documents. 2.00
FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022
NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024
Santander Bank, N.A. Client: 104673
November 30, 2023 Matter: 104673.000003
Page 2 Invoice: 916011
Date Atty Professional Services Hours
11/29/23 JB Review correspondence regarding Carrigan 0.30
deposition.
11/29/23 JB Review Carrigan deposition exhibits. 0.80
11/29/23 JB Telephone conference with J. Manning regarding 0.50
Redacted .
11/30/23 JB Review deposition exhibits. 0.50
11/30/23 JB Emails with client and counsel regarding 0.50
Redacted .
11/30/23 JB Attend BankUnited deposition. 2.60
11/30/23 JB Attend First Horizon deposition. 2.00
Total Hours 21.30
Total Current Fees $13,312.50
Current Invoice Due $13,312.50
FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022
NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024
Robert E. Bailey, Senior Deputy General Counsel
Brian M. Doyle, Associate Counsel
Santander Holdings USA, Inc.
45 East 53rd Street, 15th Floor
New York, NY 10022
File Number: 104673.000003
Please remit payment within 30 days from date of invoice
Santander Bank, N.A. Date: 01/08/24
RE: VativoRX Litigation Invoice: 917947
Client Ref: 2022-0002411
For Professional Services Rendered and Costs Advanced through 12/31/23
Date Atty Professional Services Hours
12/01/23 JB Attend Trustmark deposition. 1.30
12/01/23 JB Emails with counsel group regarding Redacted 0.50
Redacted .
12/03/23 JB Emails with counsel team regarding Redacted 0.30
Redacted .
12/03/23 JB Review exhibits regarding Redacted 0.50
Redacted .
12/04/23 JB Attend Spitzer deposition. 5.00
12/04/23 JB Emails with counsel and client regarding Redacted 0.30
Redacted .
12/05/23 JB Emails with counsel and client Redacted 1.00
Redacted .
Preview
FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024 Robert E. Bailey, Senior Deputy General Counsel Brian M. Doyle, Associate Counsel Santander Holdings USA, Inc. 45 East 53rd Street, 15th Floor New York, NY 10022 File Number: 104673.000003 Please remit payment within 30 days from date of invoice Santander Bank, N.A. Date: 12/12/22 RE: VativoRX Litigation Invoice: 886366 Client Ref: 2022-0002411 For Professional Services Rendered and Costs Advanced through 11/30/22 Date Atty Professional Services Hours 11/17/22 JB Review complaint and background through 1.00 telephone conferences and document review. 11/21/22 JB Review Redacted 2.20 Redacted through telephone conference and document review. 11/23/22 JB Emails with counsel group regarding strategy. 0.30 11/25/22 JB Emails with client and counsel regarding strategy. 0.20 11/27/22 JB Suggest revisions to complaint. 0.80 11/28/22 JB Communications call with counsel regarding 1.00 strategy Redacted . 11/28/22 JB Further communications with counsel regarding 1.00 strategy Redacted . 11/30/22 JB Suggest further edits to complaint. 0.60 Total Hours 7.10 Total Current Fees $4,437.50 Current Invoice Due $4,437.50 FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024 Santander Bank, N.A. Client: 104673 November 30, 2022 Matter: 104673.000003 Page 2 Invoice: 886366 FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024 Robert E. Bailey, Senior Deputy General Counsel Brian M. Doyle, Associate Counsel Santander Holdings USA, Inc. 45 East 53rd Street, 15th Floor New York, NY 10022 File Number: 104673.000003 Please remit payment within 30 days from date of invoice Santander Bank, N.A. Date: 01/31/23 RE: VativoRX Litigation Invoice: 888414 Client Ref: 2022-0002411 For Professional Services Rendered and Costs Advanced through 12/31/22 Date Atty Professional Services Hours 12/02/22 JB Emails with counsel regarding status. 0.20 12/06/22 JB Emails with counsel regarding status. 0.10 12/06/22 JB Review revised draft complaint. 0.30 12/07/22 JB Emails with client and counsel regarding Redacted 0.20 Redacted. Total Hours 0.80 Total Current Fees $500.00 Current Invoice Due $500.00 FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024 Robert E. Bailey, Senior Deputy General Counsel Brian M. Doyle, Associate Counsel Santander Holdings USA, Inc. 45 East 53rd Street, 15th Floor New York, NY 10022 File Number: 104673.000003 Please remit payment within 30 days from date of invoice Santander Bank, N.A. Date: 02/07/23 RE: VativoRX Litigation Invoice: 890484 Client Ref: 2022-0002411 For Professional Services Rendered and Costs Advanced through 01/31/23 Date Atty Professional Services Hours 01/23/23 JB Review motion papers. 0.80 01/23/23 JB Emails with counsel regarding strategy. 0.40 01/23/23 JB Review and revise letter to court. 0.20 01/27/23 JB Review opposition memorandum. 0.70 01/27/23 JB Emails with counsel regarding Redacted. 0.30 01/30/23 JB Emails with counsel regarding status. 0.20 01/31/23 JB Telephone conference with counsel regarding 0.70 status and strategy. 01/31/23 JB Email to client re status. 0.10 01/31/23 JB Review reply brief. 0.30 01/31/23 JB Review order on motion. 0.20 01/31/23 TLA Prepare Notice of Appearance for J. Brydges and 0.50 file same. Total Hours 4.40 Total Current Fees $2,542.50 Current Invoice Due $2,542.50 FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024 Robert E. Bailey, Senior Deputy General Counsel Brian M. Doyle, Associate Counsel Santander Holdings USA, Inc. 45 East 53rd Street, 15th Floor New York, NY 10022 File Number: 104673.000003 Please remit payment within 30 days from date of invoice Santander Bank, N.A. Date: 03/21/23 RE: VativoRX Litigation Invoice: 894327 Client Ref: 2022-0002411 For Professional Services Rendered and Costs Advanced through 02/28/23 Date Atty Professional Services Hours 02/01/23 JB Review Court filings. 0.30 02/02/23 JB Telephone conference with J. Manning regarding 0.20 Redacted 02/02/23 JB Review court filings. 0.20 02/03/23 JB Represent client attending preliminary 0.80 conference. 02/03/23 JB Emails with counsel regarding Redacted 0.30 02/06/23 JB Emails with counsel regarding Redacted 0.30 Redacted . 02/06/23 JB Revise responsive pleading. 0.20 02/06/23 JB Review Redacted 0.30 Redacted . 02/06/23 JB Review application to AD. 0.40 02/07/23 JB Emails with counsel regarding status. 0.30 02/08/23 JB Emails with counsel regarding status and Redacted 0.60 Redacted . 02/08/23 JB Telephone conference with plaintiffs' counsel 0.10 regarding strategy. 02/08/23 JB Telephone conference with all counsel regarding 0.70 Redacted. 02/09/23 JB Emails with counsel regarding Redacted 0.30 Redacted . 02/10/23 JB Review and revise stipulation. 0.30 FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024 Santander Bank, N.A. Client: 104673 February 28, 2023 Matter: 104673.000003 Page 2 Invoice: 894327 Date Atty Professional Services Hours 02/10/23 JB Emails with counsel regarding status. 0.40 02/14/23 JB Review and revise answer to counterlcaims. 0.40 02/16/23 JB Emails with counsel regarding Redacted 0.20 Redacted. 02/17/23 JB Review opposition to motion to dismiss and 0.50 discovery demands. 02/22/23 JB Review final consent order. 0.20 Total Hours 7.00 Total Current Fees $4,375.00 Current Invoice Due $4,375.00 FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024 Robert E. Bailey, Senior Deputy General Counsel Brian M. Doyle, Associate Counsel Santander Holdings USA, Inc. 45 East 53rd Street, 15th Floor New York, NY 10022 File Number: 104673.000003 Please remit payment within 30 days from date of invoice Santander Bank, N.A. Date: 05/18/23 RE: VativoRX Litigation Invoice: 898021 Client Ref: 2022-0002411 For Professional Services Rendered and Costs Advanced through 04/30/23 Date Atty Professional Services Hours 04/05/23 CFK Telephone call with J. Brydges to discuss 2.00 Redacted ; review sample Redacted ; review complaint; attend meet and confer Redacted Redacted with plaintiffs and defendant; draft summary of meet and confer. 04/06/23 CFK Review pleadings, motions, and discovery 1.50 responses to date Redacted Redacted Redacted . 04/12/23 JB Emails with plaintiffs' counsel regarding status. 0.20 04/12/23 JB Communication with client regarding status. 0.10 04/17/23 JB Review correspondence regarding discovery. 0.30 04/17/23 JB Review ediscovery protocol. 0.10 04/17/23 JB Emails with client regarding Redacted. 0.10 04/18/23 JB Telephone conference with client regarding 0.20 Redacted . 04/18/23 JB Review third party subpoenas. 0.30 04/19/23 JB Emails among team and client regarding 0.30 Redacted. 04/19/23 TLA Discuss Redacted with J. 0.40 Brydges: communicate with I. Antinoro regarding Redacted . FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024 Santander Bank, N.A. Client: 104673 April 30, 2023 Matter: 104673.000003 Page 2 Invoice: 898021 Date Atty Professional Services Hours 04/20/23 JB Emails with counsel regarding Redacted. 0.30 04/20/23 JB Emails with client regarding Redacted. 0.20 04/20/23 JB Emails with counsel regarding Redacted. 0.20 04/27/23 JB Review Redacted . 0.20 Total Hours 6.40 Total Current Fees $2,959.00 Current Invoice Due $2,959.00 FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024 Robert E. Bailey, Senior Deputy General Counsel Brian M. Doyle, Associate Counsel Santander Holdings USA, Inc. 45 East 53rd Street, 15th Floor New York, NY 10022 File Number: 104673.000003 Please remit payment within 30 days from date of invoice Santander Bank, N.A. Date: 05/18/23 RE: VativoRX Litigation Invoice: 899440 Client Ref: 2022-0002411 For Professional Services Rendered and Costs Advanced through 03/31/23 Date Atty Professional Services Hours 03/06/23 JB Emails with team regarding Redacted, review 0.70 appellate filings/review reply brief. 03/07/23 JB Telephone conference with Counsel group 0.30 regarding Redacted. 03/09/23 JB Review correspondence to borrower’s counsel. 0.20 03/10/23 JB Telephone conference with client regarding 0.20 Redacted, review interrogatory responses. 03/13/23 JB Review correspondence from borrower’s counsel. 0.20 03/16/23 JB Emails with counsel regarding Redacted 0.20 Redacted . 03/16/23 JB Emails with client re Redacted . 0.10 Redacted 03/16/23 JB Review discovery responses. 0.30 03/17/23 JB Review interrogatory responses and revise same, 0.70 emails with J . Manning regarding Redacted. 03/20/23 JB Emails with counsel regarding Redacted 0.20 Redacted . Total Hours 3.10 Total Current Fees $1,937.50 FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024 Santander Bank, N.A. Client: 104673 March 31, 2023 Matter: 104673.000003 Page 2 Invoice: 899440 Current Invoice Due $1,937.50 FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024 Robert E. Bailey, Senior Deputy General Counsel Brian M. Doyle, Associate Counsel Santander Holdings USA, Inc. 45 East 53rd Street, 15th Floor New York, NY 10022 File Number: 104673.000003 Please remit payment within 30 days from date of invoice Santander Bank, N.A. Date: 06/12/23 RE: VativoRX Litigation Invoice: 901155 Client Ref: 2022-0002411 For Professional Services Rendered and Costs Advanced through 05/31/23 Date Atty Professional Services Hours 05/02/23 JB Emails with client regarding Redacted . 0.20 05/02/23 JB Emails with counsel regarding Redacted. 0.30 05/03/23 JB Emails with counsel regarding Redacted 0.30 Redacted. 05/04/23 JB Emails with counsel regarding Redacted 0.20 Redacted. 05/05/23 JB Emails with plaintiffs group regarding Redacted 0.20 Redacted . 05/05/23 JB Draft Redacted . 0.60 05/08/23 JB Review subpoenas. 0.40 05/09/23 JB Emails with counsel regarding Redacted . 0.50 05/10/23 JB Emails with plaintiff group regarding Redacted 0.20 Redacted . 05/11/23 JB Emails with counsel regarding Redacted . 0.30 Redacted 05/15/23 JB Emails with plaintiffs’ counsel regarding Redacted 0.30 Redacted . 05/16/23 JB Emails with group regarding Redacted . 0.20 Redacted 05/18/23 JB Emails with group regarding Redacted 0.20 Redacted. 05/18/23 JB Review confidentiality stipulation and order. 0.20 05/18/23 JB Emails with I. Antinoro regarding Redacted 0.20 Redacted. 05/19/23 JB Begin review of client documents for production. 3.80 FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024 Santander Bank, N.A. Client: 104673 May 31, 2023 Matter: 104673.000003 Page 2 Invoice: 901155 Date Atty Professional Services Hours 05/22/23 JB Emails with counsel regarding Redacted. 0.30 05/22/23 JB Review client documents. 4.50 05/22/23 JB Emails with counsel regarding discovery. 0.20 05/23/23 JB Continue document review for production. 5.30 05/23/23 JB Telephone conference with client regarding 0.20 Redacted . 05/24/23 JB Continue document review. 4.50 05/25/23 JB Continue document review. 2.30 05/26/23 JB Continue document review. 2.50 05/30/23 JB Continue reviewing documents for production. 6.50 05/31/23 JB Continue document review. 3.80 05/31/23 JB Emails with counsel regarding Redacted . 0.30 Total Hours 38.50 Total Current Fees $24,062.50 Current Invoice Due $24,062.50 FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024 Robert E. Bailey, Senior Deputy General Counsel Brian M. Doyle, Associate Counsel Santander Holdings USA, Inc. 45 East 53rd Street, 15th Floor New York, NY 10022 File Number: 104673.000003 Please remit payment within 30 days from date of invoice Santander Bank, N.A. Date: 07/18/23 RE: VativoRX Litigation Invoice: 903658 Client Ref: 2022-0002411 For Professional Services Rendered and Costs Advanced through 06/30/23 Date Atty Professional Services Hours 06/01/23 JB Meeting with K. Berry regarding document 0.20 production. 06/01/23 JB Continue document review. 2.00 06/02/23 JB Continue document review. 1.20 06/05/23 JB Telephone conference with J. Manning regarding 0.20 Redacted . 06/06/23 JB Emails with counsel regarding Redacted 0.30 Redacted. 06/06/23 JB Emails with counsel regarding Redacted. 0.30 06/07/23 JB Review privileged documents and create privilege 2.00 log. 06/07/23 JB Emails with client Redacted . 0.20 Redacted 06/09/23 JB Redact documents for privilege and relevance. 5.50 06/12/23 JB Telephone conference with plaintiffs' counsel 0.60 regarding Redacted . 06/12/23 JB Review confidentiality designations. 2.00 06/13/23 JB Continue review of confidentiality designations. 2.20 06/14/23 JB Continue confidentiality review. 1.70 06/14/23 JB Emails with counsel regarding Redacted . 0.20 Redacted 06/16/23 JB Emails with counsel regarding Redacted. 0.20 06/19/23 JB Continue reviewing documents for redaction. 1.80 06/28/23 JB Review new batch of documents for production. 2.00 06/29/23 JB Finalize document production. 2.30 FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024 Santander Bank, N.A. Client: 104673 June 30, 2023 Matter: 104673.000003 Page 2 Invoice: 903658 Date Atty Professional Services Hours 06/29/23 JB Emails with K. Berry re document production. 0.20 Total Hours 25.10 Total Current Fees $15,687.50 Current Invoice Due $15,687.50 FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024 Robert E. Bailey, Senior Deputy General Counsel Brian M. Doyle, Associate Counsel Santander Holdings USA, Inc. 45 East 53rd Street, 15th Floor New York, NY 10022 File Number: 104673.000003 Please remit payment within 30 days from date of invoice Santander Bank, N.A. Date: 08/10/23 RE: VativoRX Litigation Invoice: 906202 Client Ref: 2022-0002411 For Professional Services Rendered and Costs Advanced through 07/31/23 Date Atty Professional Services Hours 07/07/23 JB Review and revise privilege logs. 1.00 07/10/23 JB Draft privilege logs. 2.30 07/11/23 JB Continue drafting privilege logs. 2.80 07/11/23 JB Emails with counsel regarding status and Redacted 0.50 . Redacted 07/12/23 JB Finalize and serve privilege logs. 2.00 07/12/23 JB Emails with team regarding Redacted . 0.30 07/12/23 JB Review co-plaintiff logs. 0.60 07/12/23 JB Review reply brief on motion to enforce. 0.30 07/14/23 JB Review plaintiff's privilege logs. 0.50 07/18/23 JB Review papers on motion to enforce. 0.50 07/21/23 JB Review defendant status letter. 0.20 07/24/23 JB Review plaintiff's response regarding status on 0.20 motion to enforce. 07/26/23 JB Emails with counsel regarding Redacted and 0.30 strategy. Total Hours 11.50 Total Current Fees $7,187.50 FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024 Santander Bank, N.A. Client: 104673 July 31, 2023 Matter: 104673.000003 Page 2 Invoice: 906202 Current Invoice Due $7,187.50 FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024 Robert E. Bailey, Senior Deputy General Counsel Brian M. Doyle, Associate Counsel Santander Holdings USA, Inc. 45 East 53rd Street, 15th Floor New York, NY 10022 File Number: 104673.000003 Please remit payment within 30 days from date of invoice Santander Bank, N.A. Date: 09/18/23 RE: VativoRX Litigation Invoice: 908886 Client Ref: 2022-0002411 For Professional Services Rendered and Costs Advanced through 08/31/23 Date Atty Professional Services Hours 08/03/23 JB Review summary judgment motion and deficiency 1.00 letter. 08/14/23 JB Review and revise pre-motion letter. 0.30 08/25/23 JB Emails with counsel regarding Redacted . 0.20 08/30/23 JB Telephone conference with team regarding 0.80 strategy. 08/30/23 JB Review Heffron deposition. 0.80 08/30/23 JB Review defendants' summary judgment motion. 1.20 08/31/23 JB Review and revise opposition brief. 0.50 08/31/23 JB Review Heffron deposition. 0.80 08/31/23 JB Emails with team regarding Redacted . 0.20 Total Hours 5.80 Total Current Fees $3,625.00 Current Invoice Due $3,625.00 FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024 Robert E. Bailey, Senior Deputy General Counsel Brian M. Doyle, Associate Counsel Santander Holdings USA, Inc. 45 East 53rd Street, 15th Floor New York, NY 10022 File Number: 104673.000003 Please remit payment within 30 days from date of invoice Santander Bank, N.A. Date: 10/23/23 RE: VativoRX Litigation Invoice: 912309 Client Ref: 2022-0002411 For Professional Services Rendered and Costs Advanced through 09/30/23 Date Atty Professional Services Hours 09/05/23 JB Emails with client regarding status. 0.20 09/05/23 JB Emails with counsel regarding Redacted. 0.20 09/06/23 JB Emails with counsel regarding Redacted . 0.20 09/06/23 JB Review reply brief draft. 0.50 09/11/23 JB Review Heffron transcript. 0.80 09/12/23 JB Review deposition notice topics. 0.30 09/12/23 JB Emails with counsel regarding Redacted. 0.20 09/13/23 JB Review deposition topics. 0.20 09/13/23 JB Emails with counsel regarding Redacted . 0.20 09/13/23 JB Telephone conference with counsel regarding 0.50 Redacted . 09/14/23 JB Emails with counsel regarding Redacted . 0.20 09/18/23 JB Emails w/ counsel re Redacted . 0.20 09/19/23 JB Emails with counsel and client regarding 0.70 Redacted . 09/20/23 JB Emails with counsel regarding Redacted . 0.30 09/20/23 JB Conference call with counsel group regarding 0.40 Redacted . 09/20/23 JB Review documents for Vativo deposition. 0.80 09/20/23 JB Review Santander production in advance of 1.60 30(b)(6) deposition. 09/21/23 JB Telephone conference with client regarding 0.20 Redacted . FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024 Santander Bank, N.A. Client: 104673 September 30, 2023 Matter: 104673.000003 Page 2 Invoice: 912309 Date Atty Professional Services Hours 09/21/23 JB Review documents to prepare for deposition. 3.00 09/21/23 JB Meet and confer with Vativo counsel regarding 1.00 depositions. 09/22/23 JB Continue document review in preparation for 1.30 deposition. 09/22/23 JB Review revised deposition notice. 0.20 09/22/23 JB Emails with group regarding Redacted . 0.30 09/25/23 JB Continue review of documents in preparation for 2.80 deposition. 09/25/23 JB Emails with counsel regarding Redacted . 0.30 09/26/23 JB Emails with plaintiffs' counsel regarding 0.50 Redacted . 09/26/23 JB Review documents for depositions. 2.60 09/27/23 JB Emails with plaintiffs’ counsel regarding Redacted 0.30 Redacted . Total Hours 20.00 Total Current Fees $12,500.00 Current Invoice Due $12,500.00 FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024 Robert E. Bailey, Senior Deputy General Counsel Brian M. Doyle, Associate Counsel Santander Holdings USA, Inc. 45 East 53rd Street, 15th Floor New York, NY 10022 File Number: 104673.000003 Please remit payment within 30 days from date of invoice Santander Bank, N.A. Date: 11/03/23 RE: VativoRX Litigation Invoice: 912741 Client Ref: 2022-0002411 For Professional Services Rendered and Costs Advanced through 10/31/23 Date Atty Professional Services Hours 10/05/23 JB Emails with counsel regarding status. 0.20 10/06/23 JB Emails with counsel regarding Redacted . 0.20 10/09/23 JB Telephone conference with plaintiffs' group 0.80 regarding Redacted . 10/12/23 JB Emails with counsel regarding Redacted . 0.20 10/12/23 JB Emails with client regarding Redacted . 0.10 10/13/23 JB Telephone conference with J. Manning regarding 0.20 Redacted . 10/16/23 JB Telephone conference with Plaintiffs’ counsel 0.50 regarding Redacted . 10/19/23 JB Emails with plaintiffs’ counsel regarding 0.30 Redacted . 10/23/23 JB Emails with counsel re Redacted . 0.30 10/24/23 JB Emails with counsel re Redacted . 0.20 10/24/23 JB Review revised deposition topics. 0.20 10/25/23 JB Telephone conference with bank counsel re 1.00 Redacted . Total Hours 4.20 Total Current Fees $2,625.00 FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024 Santander Bank, N.A. Client: 104673 October 31, 2023 Matter: 104673.000003 Page 2 Invoice: 912741 Current Invoice Due $2,625.00 FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024 Robert E. Bailey, Senior Deputy General Counsel Brian M. Doyle, Associate Counsel Santander Holdings USA, Inc. 45 East 53rd Street, 15th Floor New York, NY 10022 File Number: 104673.000003 Please remit payment within 30 days from date of invoice Santander Bank, N.A. Date: 12/12/23 RE: VativoRX Litigation Invoice: 916011 Client Ref: 2022-0002411 For Professional Services Rendered and Costs Advanced through 11/30/23 Date Atty Professional Services Hours 11/01/23 JB Emails with counsel regarding Redacted 0.20 Redacted. 11/06/23 JB Emails with counsel regarding Redacted 0.30 Redacted. 11/07/23 JB Emails with counsel regarding Redacted. 0.30 11/09/23 JB Emails with counsel regarding Redacted . 0.30 11/13/23 JB Review transcript of argument. 1.00 11/15/23 JB Emails with counsel regarding Redacted . 0.30 11/17/23 JB Emails with counsel regarding Redacted 0.30 Redacted. 11/20/23 JB Continue document review in preparation for 2.00 Millman deposition. 11/20/23 JB T/c with J. Manning regarding Redacted . 0.30 11/21/23 JB Emails with client regarding Redacted . 0.30 11/27/23 JB Review Regions documents for depositions. 1.00 11/27/23 JB Prepare outline for Redacted . 2.00 11/27/23 JB Telephone conference with J. Manning regarding 1.00 Redacted . 11/27/23 JB Emails with B. Emmons regarding Redacted . 0.30 11/28/23 JB Prepare for meeting with J. Millman 1.50 11/28/23 JB Telephone conference with J. Millman and B. 1.00 Emmons regarding Redacted . 11/28/23 JB Review additional production documents. 2.00 FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024 Santander Bank, N.A. Client: 104673 November 30, 2023 Matter: 104673.000003 Page 2 Invoice: 916011 Date Atty Professional Services Hours 11/29/23 JB Review correspondence regarding Carrigan 0.30 deposition. 11/29/23 JB Review Carrigan deposition exhibits. 0.80 11/29/23 JB Telephone conference with J. Manning regarding 0.50 Redacted . 11/30/23 JB Review deposition exhibits. 0.50 11/30/23 JB Emails with client and counsel regarding 0.50 Redacted . 11/30/23 JB Attend BankUnited deposition. 2.60 11/30/23 JB Attend First Horizon deposition. 2.00 Total Hours 21.30 Total Current Fees $13,312.50 Current Invoice Due $13,312.50 FILED: NEW YORK COUNTY CLERK 04/12/2024 06:45 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 311 RECEIVED NYSCEF: 04/12/2024 Robert E. Bailey, Senior Deputy General Counsel Brian M. Doyle, Associate Counsel Santander Holdings USA, Inc. 45 East 53rd Street, 15th Floor New York, NY 10022 File Number: 104673.000003 Please remit payment within 30 days from date of invoice Santander Bank, N.A. Date: 01/08/24 RE: VativoRX Litigation Invoice: 917947 Client Ref: 2022-0002411 For Professional Services Rendered and Costs Advanced through 12/31/23 Date Atty Professional Services Hours 12/01/23 JB Attend Trustmark deposition. 1.30 12/01/23 JB Emails with counsel group regarding Redacted 0.50 Redacted . 12/03/23 JB Emails with counsel team regarding Redacted 0.30 Redacted . 12/03/23 JB Review exhibits regarding Redacted 0.50 Redacted . 12/04/23 JB Attend Spitzer deposition. 5.00 12/04/23 JB Emails with counsel and client regarding Redacted 0.30 Redacted . 12/05/23 JB Emails with counsel and client Redacted 1.00 Redacted .