Preview
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