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  • Regions Bank, Bankunited, N.A., First Horizon Bank, Trustmark National Bank, Santander Bank, N.A. v. Vativorx, LlcCommercial - Contract - Commercial Division document preview
  • Regions Bank, Bankunited, N.A., First Horizon Bank, Trustmark National Bank, Santander Bank, N.A. v. Vativorx, LlcCommercial - Contract - Commercial Division document preview
  • Regions Bank, Bankunited, N.A., First Horizon Bank, Trustmark National Bank, Santander Bank, N.A. v. Vativorx, LlcCommercial - Contract - Commercial Division document preview
  • Regions Bank, Bankunited, N.A., First Horizon Bank, Trustmark National Bank, Santander Bank, N.A. v. Vativorx, LlcCommercial - Contract - Commercial Division document preview
  • Regions Bank, Bankunited, N.A., First Horizon Bank, Trustmark National Bank, Santander Bank, N.A. v. Vativorx, LlcCommercial - Contract - Commercial Division document preview
  • Regions Bank, Bankunited, N.A., First Horizon Bank, Trustmark National Bank, Santander Bank, N.A. v. Vativorx, LlcCommercial - Contract - Commercial Division document preview
  • Regions Bank, Bankunited, N.A., First Horizon Bank, Trustmark National Bank, Santander Bank, N.A. v. Vativorx, LlcCommercial - Contract - Commercial Division document preview
  • Regions Bank, Bankunited, N.A., First Horizon Bank, Trustmark National Bank, Santander Bank, N.A. v. Vativorx, LlcCommercial - Contract - Commercial Division document preview
						
                                

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FILED: NEW YORK COUNTY CLERK 04/12/2024 06:55 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 314 RECEIVED NYSCEF: 04/12/2024 Schatz Affirmation Exhibit A (combined WMD invoices) FILED: NEW YORK COUNTY CLERK 04/12/2024 06:55 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 314 RECEIVED NYSCEF: 04/12/2024 WOLLMUTH MAHER & DEUTSCH LLP 500 FIFTH AVENUE NEW YORK, NY 10110 TAXPAYER I.D Bill To: Invoice Date 3/10/2023 First Horizon Bank Invoice Number 00002184 211 Franklin Road Brentwood, TN 37027 United States In reference to: 7408-001 | First Horizon Bank | Regions Bank et al. v. VativoRx LLC, NY Supreme Professional Services Rendered Date Staff Description Hours Rate Amount Review draft complaint and exhibits to approve form for filing; 12/8/2022 PRS 0.4 $875.00 $350.00 emails ref. same. Download and review complaint and exhibits; create case binder 12/9/2022 PRS 1.7 $875.00 $1,487.50 and Litify case file. 12/12/2022 PRS Emails ref. complaint. Search database for new filing. 0.3 $875.00 $262.50 Review NYSCEF website for complaint; review and file filed 12/15/2022 PRS 0.3 $875.00 $262.50 complaint and supporting documents. 12/20/2022 PRS Review emails and attachments for filing, follow-up, destruction. 0.1 $875.00 $87.50 Review and analysis of email from Jim Manning and attachments 12/21/2022 PRS concerning assignment to Justice Crane, affidavit of service, and 0.2 $875.00 $175.00 preservation letter. Review email from PRS, and relevant documents re case 1/20/2023 KJH 0.3 $600.00 $180.00 onboarding Review and analysis of memorandum ref. litigation status; update 1/20/2023 PRS case files; emails ref. same. Assign review and report to Mr. Hale. 1.6 $910.00 $1,456.00 Emails, discussions, research and document review ref. same. Review Complaint and supporting exhibits, Motion to Dismiss, Answer and Counter Claims and supporting affidavits for case onboarding and preparation for discussion with PRS; legal 1/23/2023 KJH 6.6 $600.00 $3,960.00 research re counter claims of tortious interference with contract and prospective business advantage; email w/ PRS re discussion of issues 1/23/2023 PRS Review MTD and answer. Emails ref. same. 0.9 $910.00 $819.00 O/c w/ PRS re case onboarding, casefile organization, counterclaims by defendants, legal research project re economic justification defense to tortious interference counterclaim; legal 1/24/2023 KJH 5.6 $600.00 $3,360.00 research project re economic justification defense to tortious interference counterclaim; o/c w/ PRS re findings for same, and re additional searches; reorganize casefile per PRS instruction Discussions ref. strategy, review and analysis of recent filings, 1/24/2023 PRS 0.8 $910.00 $728.00 update binder. 1/25/2023 PRS Discussions and emails ref. strategy and planning. 0.6 $910.00 $546.00 1/27/2023 PRS Review draft brief and emails ref. same, respond to emails. 0.3 $910.00 $273.00 Emails ref. strategy meeting; file review and calendaring ref. 1/30/2023 PRS 0.2 $910.00 $182.00 same Emails and discussions ref. strategy and coverage; review memo 1/31/2023 PRS 0.6 $910.00 $546.00 of todays call; file review and analysis ref. same. Review and analysis of emails and attachments; file management; FILED: NEW YORK COUNTY CLERK 04/12/2024 06:55 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 314 RECEIVED NYSCEF: 04/12/2024 2/1/2023 PRS calendaring for injunction hearing 0.3 $910.00 $273.00 2/2/2023 ATC E-file NOAs re. PRS and KJH to NY Supreme Court 0.3 $235.00 $70.50 Prepare notices of appearance for PRS, KJH; email w/ PRS re 2/2/2023 KJH same; email w/ AKC re filing; research re standard for injunctive 1.6 $600.00 $960.00 relief from appellate division Email Manning ref. tomorrow's court conference; t/cs Mr. Manning; arrange for filing of notice of appearance; review 2/2/2023 PRS appeal papers; direct research ref. appellate division applications 1.1 $910.00 $1,001.00 for stay; locate pro-hac papers; research, document review, emails, t/cs, and discussions ref. same. Research re requirements for grant of TRO in Appellate Division; 2/3/2023 KJH 1.8 $600.00 $1,080.00 email w/ PRS re same; Preparation for and attendance at court appearance; follow-up ref. 2/3/2023 PRS 1.4 $910.00 $1,274.00 same. Emails ref. court appearance; research and document review ref. 2/6/2023 PRS 0.5 $910.00 $455.00 same. 2/7/2023 PRS Emails and discussions ref. conference 0.2 $910.00 $182.00 2/8/2023 PRS Emails ref. plaintiffs' t/conference and strategy; file maintenance. 0.2 $910.00 $182.00 2/9/2023 PRS Emails ref. court conferences and strategy ref. same. 0.2 $910.00 $182.00 Review and analysis of consent order and drafts of consent order; 2/10/2023 PRS 0.7 $910.00 $637.00 research and emails ref. same. Review and analysis of draft answer; research and draft 2/14/2023 PRS comments to draft; review and analysis of other lawyer's 1.1 $910.00 $1,001.00 comments to draft; emails and t/cs ref. same. 2/15/2023 PRS Review comments and emails ref. answer to counterclaims. 0.2 $910.00 $182.00 2/16/2023 PRS Emails and discussions, review and analysis of court filings. 0.3 $910.00 $273.00 Review decision on sealing motion; review correspondence and attachment; review and analysis of discovery demands; review 2/17/2023 PRS 0.9 $910.00 $819.00 Comm Div rules; review correspondence ref. Vativo backtracking; emails ref. same. Email w/ PRS re Motion for admission pro hac vice for J. Sveadas; prepare affidavit of J. Sveadas, Affirmation of PRS, 2/21/2023 KJH 2.8 $600.00 $1,680.00 Proposed Order; order to show cause; email w/ PRS re finished drafts and comments Emails ref. pro-hac admission; review and revise pro-hac 2/21/2023 PRS 1.1 $910.00 $1,001.00 application; t/c, emails, and discussions ref. same. Email w/ PRS re revisions to PHV motion; revise PHV motion 2/22/2023 KJH for J. Sveadas; email w/ J. Sveadas and PRS re finalized drafts for 1.8 $600.00 $1,080.00 J. Sveadas review 2/22/2023 PRS Review and revise pro-hac papers; research and emails ref. same. 0.8 $910.00 $728.00 2/23/2023 PRS Review and sign consent order; emails ref. same. 0.3 $910.00 $273.00 Services Total $28,008.50 Payments and Credits Including Retainer Applied $25,207.65 Net Amount Due $0.00 Total including Prior Open Invoices $29,727.50 FILED: NEW YORK COUNTY CLERK 04/12/2024 06:55 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 314 RECEIVED NYSCEF: 04/12/2024 Timekeeper Summary TIMEKEEPER HOURS RATE TOTAL Philip Schatz, Partner 3.00 $875.00 $2,625.00 Kevin Hale, Associate 20.50 $600.00 $12,300.00 Philip Schatz, Partner 14.30 $910.00 $13,013.00 Alex Cukier, Paralegal 0.30 $235.00 $70.50 TOTAL 38.10 $28,008.50 Outstanding Invoices Received Billing Date Inv # Services Disbursements Invoice Total Balance Amount 3/8/2024 00003779 $1,719.00 $0.00 $1,719.00 $0.00 $1,719.00 $1,719.00 $0.00 $1,719.00 $0.00 $1,719.00 FILED: NEW YORK COUNTY CLERK 04/12/2024 06:55 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 314 RECEIVED NYSCEF: 04/12/2024 FILED: NEW YORK COUNTY CLERK 04/12/2024 06:55 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 314 RECEIVED NYSCEF: 04/12/2024 WOLLMUTH MAHER & DEUTSCH LLP 500 FIFTH AVENUE NEW YORK, NY 10110 TAXPAYER I.D Bill To: Invoice Date 5/5/2023 First Horizon Bank Invoice Number 00002426 211 Franklin Road Brentwood, TN 37027 United States In reference to: 7408-001 | First Horizon Bank | Regions Bank et al. v. VativoRx LLC, NY Supreme Professional Services Rendered Date Staff Description Hours Rate Amount 3/1/2023 PRS Emails and discussions ref. case status; draft follow-up 0.2 $910.00 $182.00 3/2/2023 PRS Review new court filing. 0.1 $910.00 $91.00 Review and analysis of interrogatories and document requests and 3/6/2023 PRS request for t/conf ref. same; research, document review, and 0.8 $910.00 $728.00 emails ref. same. 3/7/2023 PRS Emails and t/c ref discovery responses. 0.2 $910.00 $182.00 Review and analysis of correspondence and attachments; 3/10/2023 PRS 2.1 $910.00 $1,911.00 preparation and attendance at t/conf. Review and analysis of correspondence and attachments; research 3/13/2023 PRS 0.5 $910.00 $455.00 and emails ref. discovery responses and objections Locate and review exemplar responses and objections; review 3/14/2023 PRS 1.3 $910.00 $1,183.00 document demands and interrogatories for objections Review and comment on document responses and objections; 3/16/2023 PRS 1.7 $910.00 $1,547.00 emails, research, and document review ref. same. Review Manning email and attachment; review related materials; 3/17/2023 PRS 0.4 $910.00 $364.00 email and t/c ref. same. Review and analysis of revised interrogatory responses and document responses, and emails with changes and comments ref. 3/20/2023 PRS 1.3 $910.00 $1,183.00 same. T/cs ref. finalization and verification. Research and draft email ref. verification; follow-up emails ref. same. 3/21/2023 PRS Review served discovery documents; emails ref. same. 0.4 $910.00 $364.00 Review and analysis of emails, attachments, draft responses, and 3/27/2023 PRS 0.2 $910.00 $182.00 other communications ref. same. 3/28/2023 PRS Review correspondence; document review ref. same. 0.3 $910.00 $273.00 Review and analysis of communications regarding new 3/29/2023 PRS 0.2 $910.00 $182.00 developments. 4/4/2023 PRS Emails ref. discovery meet-and-confer. 0.2 $910.00 $182.00 Preparation for, attendance at, follow-up ref. meet-and-confer 4/5/2023 PRS 1.5 $910.00 $1,365.00 Teams meeting; follow-up emails ref. same 4/6/2023 PRS Emails and file management 0.2 $910.00 $182.00 4/7/2023 PRS Emails ref. meet-and-confer and follow-up. 0.1 $910.00 $91.00 4/18/2023 PRS Emails ref. discovery issues 0.2 $910.00 $182.00 Review draft third-party subpoenas; suggest formatting changes and revisions to conform to New York practice and to avoid 4/18/2023 PRS 0.9 $910.00 $819.00 overbreadth, vagueness, and compound objections; emails ref. same. 4/20/2023 PRS Emails ref. discovery issues 0.2 $910.00 $182.00 FILED: NEW YORK COUNTY CLERK 04/12/2024 06:55 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 314 RECEIVED NYSCEF: 04/12/2024 4/24/2023 PRS Review printed emails and attachments for action, filing, 0.2 $910.00 $182.00 follow-up. 4/27/2023 PRS Review status report 0.2 $910.00 $182.00 Services Total $12,194.00 Payments and Credits Including Retainer Applied $12,194.00 Net Amount Due $0.00 Total including Prior Open Invoices $13,913.00 FILED: NEW YORK COUNTY CLERK 04/12/2024 06:55 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 314 RECEIVED NYSCEF: 04/12/2024 Timekeeper Summary TIMEKEEPER HOURS RATE TOTAL Philip Schatz, Partner 13.40 $910.00 $12,194.00 TOTAL 13.40 $12,194.00 Outstanding Invoices Received Billing Date Inv # Services Disbursements Invoice Total Balance Amount 3/8/2024 00003779 $1,719.00 $0.00 $1,719.00 $0.00 $1,719.00 $1,719.00 $0.00 $1,719.00 $0.00 $1,719.00 FILED: NEW YORK COUNTY CLERK 04/12/2024 06:55 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 314 RECEIVED NYSCEF: 04/12/2024 FILED: NEW YORK COUNTY CLERK 04/12/2024 06:55 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 314 RECEIVED NYSCEF: 04/12/2024 WOLLMUTH MAHER & DEUTSCH LLP 500 FIFTH AVENUE NEW YORK, NY 10110 TAXPAYER I.D Bill To: Invoice Date 6/6/2023 First Horizon Bank Invoice Number 00002540 211 Franklin Road Brentwood, TN 37027 United States In reference to: 7408-001 | First Horizon Bank | Regions Bank et al. v. VativoRx LLC, NY Supreme Professional Services Rendered Date Staff Description Hours Rate Amount Review new Reed case; send precis to Mr. Manning and Mr. 5/1/2023 PRS 0.2 $910.00 $182.00 Sveadas 5/3/2023 PRS Emails and t/cs ref. filings. 0.2 $910.00 $182.00 5/4/2023 PRS Review updated draft of stipulation; emails ref. same. 0.2 $910.00 $182.00 Preparation for and attendance at t/conference, follow-up ref. 5/5/2023 PRS same; review and respond to Sveadas email ref. search 0.6 $910.00 $546.00 parameters. 5/8/2023 PRS Review non-party subpoenas and correspondence ref. same 0.2 $910.00 $182.00 Review new subpoenas; review and analysis of proposed search 5/9/2023 PRS terms and correspondence ref. same; calendaring, emails, 0.5 $910.00 $455.00 document review, and file maintenance. 5/10/2023 PRS Emails and document review ref. discovery 0.2 $910.00 $182.00 Emails and document review ref. discovery; calendar meeting 5/11/2023 PRS 0.3 $910.00 $273.00 next week. Review correspondence and emails concerning discovery disputes 5/12/2023 PRS 0.2 $910.00 $182.00 and violation of consent order. Review and analysis of correspondence ref. discovery issues and 5/15/2023 PRS 0.5 $910.00 $455.00 disputes, cases ref. same; emails ref. same. Review and analysis of correspondence and emails ref. discovery 5/16/2023 PRS 0.2 $910.00 $182.00 disputes Emails ref. search terms, confidentiality stipulation and order; 5/18/2023 PRS 0.3 $910.00 $273.00 review documents related to same. 5/19/2023 PRS Emails ref. discovery issues 0.2 $910.00 $182.00 Emails and discussions ref. oral argument, review and analysis of 5/22/2023 PRS 0.6 $910.00 $546.00 correspondence and attachments ref. discovery issues Review correspondence ref. noncompliance with settlement 5/24/2023 PRS 0.2 $910.00 $182.00 stipulation. Review draft filings; review comments to same; review new 5/25/2023 PRS 0.4 $910.00 $364.00 filings Review and analysis of drafts and final versions of plaintiffs' 5/26/2023 PRS discovery letter to Justice Crane, review defendants final 0.3 $910.00 $273.00 discovery letter to Justice Crane Emails and discussions ref. court order and discovery issues, oral 5/31/2023 PRS 0.6 $910.00 $546.00 argument and telephonic participation Services Total $5,369.00 FILED: NEW YORK COUNTY CLERK 04/12/2024 06:55 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 314 RECEIVED NYSCEF: 04/12/2024 Payments and Credits Including Retainer Applied $5,369.00 Net Amount Due $0.00 Total including Prior Open Invoices $7,088.00 FILED: NEW YORK COUNTY CLERK 04/12/2024 06:55 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 314 RECEIVED NYSCEF: 04/12/2024 Timekeeper Summary TIMEKEEPER HOURS RATE TOTAL Philip Schatz, Partner 5.90 $910.00 $5,369.00 TOTAL 5.90 $5,369.00 Outstanding Invoices Received Billing Date Inv # Services Disbursements Invoice Total Balance Amount 3/8/2024 00003779 $1,719.00 $0.00 $1,719.00 $0.00 $1,719.00 $1,719.00 $0.00 $1,719.00 $0.00 $1,719.00 FILED: NEW YORK COUNTY CLERK 04/12/2024 06:55 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 314 RECEIVED NYSCEF: 04/12/2024 FILED: NEW YORK COUNTY CLERK 04/12/2024 06:55 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 314 RECEIVED NYSCEF: 04/12/2024 WOLLMUTH MAHER & DEUTSCH LLP 500 FIFTH AVENUE NEW YORK, NY 10110 TAXPAYER I.D Bill To: Invoice Date 7/11/2023 First Horizon Bank Invoice Number 00002785 211 Franklin Road Brentwood, TN 37027 United States In reference to: 7408-001 | First Horizon Bank | Regions Bank et al. v. VativoRx LLC, NY Supreme Professional Services Rendered Date Staff Description Hours Rate Amount Oral argument; t/c Manning; t/c Sveados; review decision and 6/5/2023 PRS 0.8 $910.00 $728.00 emails ref. same Preparation for and t/conf. ref. operating account dispute; emails 6/14/2023 PRS 1.1 $910.00 $1,001.00 ref. same. 6/16/2023 PRS Review and approve letter to court; emails ref. same 0.2 $910.00 $182.00 6/21/2023 PRS Review and calendar entered order 0.1 $910.00 $91.00 Review and analysis of draft OSC and supporting papers; make 6/26/2023 PRS 0.5 $910.00 $455.00 suggestions ref. same; review filed papers; emails ref. same. 6/27/2023 PRS Emails ref. motion. 0.1 $910.00 $91.00 6/29/2023 PRS Review and analysis of emails and attachments; calendaring. 0.3 $910.00 $273.00 Review document production emails; calendaring and file 6/30/2023 PRS 0.4 $910.00 $364.00 maintenance ref. same Services Total $3,185.00 Payments and Credits Including Retainer Applied $3,185.00 Net Amount Due $0.00 Total including Prior Open Invoices $4,904.00 FILED: NEW YORK COUNTY CLERK 04/12/2024 06:55 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 314 RECEIVED NYSCEF: 04/12/2024 Timekeeper Summary TIMEKEEPER HOURS RATE TOTAL Philip Schatz, Partner 3.50 $910.00 $3,185.00 TOTAL 3.50 $3,185.00 Outstanding Invoices Received Billing Date Inv # Services Disbursements Invoice Total Balance Amount 3/8/2024 00003779 $1,719.00 $0.00 $1,719.00 $0.00 $1,719.00 $1,719.00 $0.00 $1,719.00 $0.00 $1,719.00 FILED: NEW YORK COUNTY CLERK 04/12/2024 06:55 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 314 RECEIVED NYSCEF: 04/12/2024 FILED: NEW YORK COUNTY CLERK 04/12/2024 06:55 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 314 RECEIVED NYSCEF: 04/12/2024 WOLLMUTH MAHER & DEUTSCH LLP 500 FIFTH AVENUE NEW YORK, NY 10110 TAXPAYER I.D Bill To: Invoice Date 8/7/2023 First Horizon Bank Invoice Number 00002922 211 Franklin Road Brentwood, TN 37027 United States In reference to: 7408-001 | First Horizon Bank | Regions Bank et al. v. VativoRx LLC, NY Supreme Professional Services Rendered Date Staff Description Hours Rate Amount 7/5/2023 PRS Review and analysis of emails and attachments. 0.2 $910.00 $182.00 7/6/2023 PRS Download, review and circulate opposition brief and exhibits 0.4 $910.00 $364.00 Emails ref. discovery issues; review and analysis of draft reply 7/11/2023 PRS 1.2 $910.00 $1,092.00 brief; edit brief and send suggestions to receiver's counsel. 7/12/2023 PRS Emails ref. productions, logs; review filed brief 0.3 $910.00 $273.00 7/18/2023 PRS Emails ref. argument, discovery issues 0.1 $910.00 $91.00 7/20/2023 PRS Calendaring and planning 0.3 $910.00 $273.00 7/24/2023 KJH Email w/ PRS re KJH coverage of 7/25 hearing 0.1 $600.00 $60.00 Review and analysis of Bloom letter. Emails ref. court 7/24/2023 PRS 0.6 $910.00 $546.00 appearance. Review and analysis of Manning response. Attend hearing before Justice Crane re Defendant violation of consent order; prepare summary of hearing and email w/ PRS re 7/25/2023 KJH 2.6 $600.00 $1,560.00 same; prepare transcript notes and summary and email w/ J. Sveadas re same Review and comment on summary of oral argument; review court 7/25/2023 PRS 0.3 $910.00 $273.00 order; emails ref. same. Download and send decision on motion; calendaring and file 7/26/2023 PRS 0.2 $910.00 $182.00 maintenance. Services Total $4,896.00 Payments and Credits Including Retainer Applied $4,896.00 Net Amount Due $0.00 Total including Prior Open Invoices $6,615.00 FILED: NEW YORK COUNTY CLERK 04/12/2024 06:55 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 314 RECEIVED NYSCEF: 04/12/2024 Timekeeper Summary TIMEKEEPER HOURS RATE TOTAL Philip Schatz, Partner 3.60 $910.00 $3,276.00 Kevin Hale, Associate 2.70 $600.00 $1,620.00 TOTAL 6.30 $4,896.00 Outstanding Invoices Received Billing Date Inv # Services Disbursements Invoice Total Balance Amount 3/8/2024 00003779 $1,719.00 $0.00 $1,719.00 $0.00 $1,719.00 $1,719.00 $0.00 $1,719.00 $0.00 $1,719.00 FILED: NEW YORK COUNTY CLERK 04/12/2024 06:55 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 314 RECEIVED NYSCEF: 04/12/2024 FILED: NEW YORK COUNTY CLERK 04/12/2024 06:55 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 314 RECEIVED NYSCEF: 04/12/2024 WOLLMUTH MAHER & DEUTSCH LLP 500 FIFTH AVENUE NEW YORK, NY 10110 TAXPAYER I.D Bill To: Invoice Date 9/7/2023 First Horizon Bank Invoice Number 00003025 211 Franklin Road Brentwood, TN 37027 United States In reference to: 7408-001 | First Horizon Bank | Regions Bank et al. v. VativoRx LLC, NY Supreme Professional Services Rendered Date Staff Description Hours Rate Amount Review deposition correspondence; review motion for summary 8/3/2023 PRS 0.4 $910.00 $364.00 judgment; review document deficiency letter; emails ref. same. 8/9/2023 PRS Review correspondence and markups of draft SJ brief 0.3 $910.00 $273.00 8/10/2023 PRS Review communications with court. 0.1 $910.00 $91.00 Emails ref. briefing and depositions; review attachments; 8/11/2023 PRS 0.2 $910.00 $182.00 calendaring ref. same. 8/14/2023 PRS Review premotion letter and response, revised SJ draft 0.3 $910.00 $273.00 Pre-motion conference with Justice Crane; emails and discussions 8/15/2023 PRS 0.4 $910.00 $364.00 ref. same. 8/18/2023 PRS Review filed papers 0.2 $910.00 $182.00 Review and analysis of motion papers and cross-motion papers; 8/23/2023 PRS 0.7 $910.00 $637.00 emails ref. same; arrange for review of cited caselaw. Review and analysis of Defendants’ summary judgment brief and supporting cases; draft memorandum concerning important cases 8/25/2023 KJH 4.8 $600.00 $2,880.00 and issues identified by PRS; research, discussions, and emails regarding the brief, cases, and memorandum 8/25/2023 PRS Read discovery letter; email Mr. Sveadas ref. same. 0.2 $910.00 $182.00 Review and analysis of summary judgment case analysis by KH 8/28/2023 PRS 0.6 $910.00 $546.00 and underlying cases; emails, discussions, and research ref. same. 8/30/2023 PRS Emails ref. status conference 0.1 $910.00 $91.00 8/31/2023 PRS Review brief; emails ref. same. 0.4 $910.00 $364.00 Services Total $6,429.00 Payments and Credits Including Retainer Applied $6,429.00 Net Amount Due $0.00 Total including Prior Open Invoices $8,148.00 FILED: NEW YORK COUNTY CLERK 04/12/2024 06:55 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 314 RECEIVED NYSCEF: 04/12/2024 Timekeeper Summary TIMEKEEPER HOURS RATE TOTAL Philip Schatz, Partner 3.90 $910.00 $3,549.00 Kevin Hale, Associate 4.80 $600.00 $2,880.00 TOTAL 8.70 $6,429.00 Outstanding Invoices Received Billing Date Inv # Services Disbursements Invoice Total Balance Amount 3/8/2024 00003779 $1,719.00 $0.00 $1,719.00 $0.00 $1,719.00 $1,719.00 $0.00 $1,719.00 $0.00 $1,719.00 FILED: NEW YORK COUNTY CLERK 04/12/2024 06:55 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 314 RECEIVED NYSCEF: 04/12/2024 FILED: NEW YORK COUNTY CLERK 04/12/2024 06:55 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 314 RECEIVED NYSCEF: 04/12/2024 WOLLMUTH MAHER & DEUTSCH LLP 500 FIFTH AVENUE NEW YORK, NY 10110 TAXPAYER I.D Bill To: Invoice Date 10/9/2023 First Horizon Bank Invoice Number 00003157 211 Franklin Road Brentwood, TN 37027 United States In reference to: 7408-001 | First Horizon Bank | Regions Bank et al. v. VativoRx LLC, NY Supreme Professional Services Rendered Date Staff Description Hours Rate Amount Skim brief; emails ref. same. Skim deposition notices; emails ref. 9/1/2023 PRS 0.4 $910.00 $364.00 same. Review and comment on proposed stipulation. Review new 9/5/2023 PRS filings. Research ref. entity depositions under New York law; 0.8 $910.00 $728.00 emails ref. same. Review and analysis of revised stipulation to extend deadlines; 9/6/2023 PRS review and analysis of revised summary judgment brief and 0.4 $910.00 $364.00 revisions; emails ref. same. Review and analysis of reply brief, spot check cases and emails 9/7/2023 PRS 0.4 $910.00 $364.00 ref. same; review proposed scheduling order Review court order; compare to filed stip; emails and calendaring 9/8/2023 PRS 0.1 $910.00 $91.00 ref. same. Review and analysis of First Horizon deposition notices and 9/12/2023 PRS notices to other plaintiff banks, compare to applicable rules; 0.3 $910.00 $273.00 calendaring, emails and discussions ref. same. Review and analysis of deposition transcript, affirmative deposition notices, and defensive deposition notices; emails ref. 9/13/2023 PRS 1.3 $910.00 $1,183.00 same; preparation for and attendance at t/conf. with plaintiffs' counsel; t/c Mr. Sveadas ref. same; emails ref. pro hac procedures Review and analysis of Parnham email ref. deposition scheduling; 9/19/2023 PRS discussions and emails ref. deposition scheduling and planning; 0.7 $910.00 $637.00 calendaring ref. same. 9/20/2023 PRS Emails ref. defendants' deposition correspondence, call ref. same 0.1 $910.00 $91.00 9/21/2023 PRS Review emails and attachments for further action 0.1 $910.00 $91.00 Review notice of deposition to VativoRx; emails ref. deposition 9/22/2023 PRS topics and scheduling, meet and confer with Parham, and 0.2 $910.00 $182.00 objections to topics Emails ref. meet-and-confer today with VativoRx and banks, 9/25/2023 PRS deposition scheduling, adjournment of noticed depositions against 0.4 $910.00 $364.00 participant banks, Review and analysis of proposed stipulation and cover letter; 9/26/2023 PRS review against prior orders and