Free Reply to Response to Motion - District Court of Colorado - Colorado

Case 1:04-cv-01258-LTB-BNB

Document 151-7

Filed 10/19/2005

Page 1 of 18

STUDENT MARKETING GROUP, INC. v. COLLEGE PARTNERSHIP, INC., f/k/a COLLEGE BOUND STUDENT ALLIANCE, INC.,

EXHIBIT 1 TO AFFIDAVIT OF R. DANIEL SCHEID STUDENT MARKETING GROUP, INC.'S REPLY TO DEFENDANT'S RESPONSE IN OPPOSITION TO PLAINTIFF'S MOTION FOR ATTORNEYS FEES

_______________
EXHIBIT 1:04-cv-1258-LTB-BNB

Case 1:04-cv-01258-LTB-BNB

Document 151-7

Filed 10/19/2005

Page 2 of 18

Local Counsel's Detailed Time Entries For SMG

I. Walsworth

06/10/2004

06/11/2004

06/14/2004

06/14/2004

06/15/2004

06/16/2004

Discussion with D. Karg; Assemble and transmit local rules and forms regarding TROs; Discussion with D. Karg (voice-mail) regarding same. Discussion with D. Karg (voice-mail); Review proposed Complaint; Prepare comments; Discussion with D. Karg regarding same; Transmit comments and local forms. Review correspondence and draft of Complaint; Review contract and discuss legal issues concerning injunctive relief with D. Scheid. Review TRO pleadings and exhibits; Discussion with D. Karg regarding same; Review draft brief in support of TRO; Further discussion with D. Karg regarding same; Transmit additional case authorities and sample motion for expedited discovery; Discussion with G. Parish regarding anticipated filing and potential TRO issues. Review e-mails and transmitted documents; Discussion with D. Karg regarding status and strategy; Discussion with P. Bates regarding anticipated filing, service, and copying. Discussion with D. Karg (voice-mail) regarding new status; Review revised Complaint; Discussion with D. Karg (voice-mail) regarding comments. Discussion with P. McElhinny regarding TRO issues; Discussion with D. Karg regarding same; Review and execute pleadings; Discussion with D. Karg regarding various issues regarding pleadings and exhibits; Arrange for copying and assembly of necessary pleadings packages for anticipated filing and service.

0.80

0.90

0.80

1.70

0.80

0.30

06/17/2004

1.90

J. Cleveland

G. E. Parish

Date

Detail

C. Krough

D. Scheid

Page 1

Case 1:04-cv-01258-LTB-BNB

Document 151-7

Filed 10/19/2005

Page 3 of 18

Local Counsel's Detailed Time Entries For SMG

I. Walsworth

06/18/2004

06/21/2004

06/22/2004

06/23/2004

Discussion with D. Karg regarding hearing status; Review correspondence from opposing counsel; Further discussion with P. McElhinny and D. Karg regarding status of settlement negotiations and anticipated filing; File Complaint and related TRO pleadings at U.S. District Court; Arrange for service of process; Further discussion with P. McElhinny regarding status of settlement possibilities and TRO setting. Discussion with Judge Matsch's secretary (voicemail) regarding potential hearing date; Discussion with P. McElhinny regarding same. Discussion with P. McElhinny regarding court contacts and hearing status; Discussion with U.S. District Court clerk regarding transfer of case to Judge Babcock; Discussion with P. McElhinny regarding same; Further discussion with P. McElhinny and Judge Babcock's clerk regarding Thursday setting and subsequent re-setting due to commencement of mailing activity; Further discussion with P. McElhinny regarding preparation for TRO hearing and potential bond issues; Discussion with bond company regarding same; Prepare potential exhibits; Attend TRO hearing as local counsel; Subsequent discussion with P. McElhinny regarding bond and scheduling order issues; Assemble and transmit scheduling order forms; Further discussion with bond company regarding financial statements required. Discussion with bond company; Discussion with court clerk; Review bond forms; Prepare transmittal to P. McElhinny; Discussion with D. Karg regarding same.

2.70

0.40

4.80

0.80

J. Cleveland

G. E. Parish

Date

Detail

C. Krough

D. Scheid

Page 2

Case 1:04-cv-01258-LTB-BNB

Document 151-7

Filed 10/19/2005

Page 4 of 18

Local Counsel's Detailed Time Entries For SMG

I. Walsworth

06/24/2004

Review e-mails; Discussion with bond company regarding quote; Review Expedited Motion for Reconsideration filed by Defendant; Discussion with P. McElhinny regarding same; Review and edit draft Scheduling Order; Discussion with D. Karg regarding same; Discussion with P. McElhinny and court clerk regarding denial of Motion for Reconsideration; Further discussion with bond company regarding final quote; Review e-mail and draft opposition brief. Review revised Scheduling Order; Discussion with D. Karg (voice-mail) regarding status of settlement talks. Discussion with D. Karg and P. McElhinny (voicemail) regarding stipulated permanent injunction and elimination of bond requirement; Further discussion with D. Karg regarding status; Review and edit stipulated order regarding preliminary injunction and confidentiality stipulation; Discussion with D. Karg regarding same. Review revised orders; Discussion with D. Karg regarding status of settlement discussions; Attend hearing with Judge Babcock regarding entry of preliminary injunction; Set hearing with Magistrate Boland; Discussion with P. McElhinny regarding same; Discussion with D. Karg (voice-mail) regarding same. Discussion with D. Karg regarding preparation of motion for approval of protective order. Review e-mail from M. McElhinny regarding Stipulated Protective Order.

2.10

06/25/2004

0.30

06/28/2004

1.20

06/29/2004

2.60

06/30/2004 07/02/2004

0.20 0.10

J. Cleveland

G. E. Parish

Date

Detail

C. Krough

D. Scheid

Page 3

Case 1:04-cv-01258-LTB-BNB

Document 151-7

Filed 10/19/2005

Page 5 of 18

Local Counsel's Detailed Time Entries For SMG

I. Walsworth

07/06/2004

Review draft stipulation forwarded by M. McElhiney; Review and respond to e-mail from P. McElhinny. Discussion with D. Karg regarding status; Review and execute final documents; Discussion with M. McElhiney and D. Karg regarding final necessary revision to stipulation; Transmit documents to M. McElhiney for filing. Review signed Protective Order; Discussion with M. McElhiney to confirm vacating of hearing. Review Scheduling Order; Docket deadlines. Discussion with D. Karg regarding coverage of Rule 16/26 deadlines set by Magistrate Boland. Review draft Scheduling Order; Discussion with D. Karg regarding same. Review and edit Confidential Settlement Statement and Rule 26 Disclosures; Discussion with D. Karg regarding same. Discussion with D. Karg; Review, finalize, execute, and file confidential settlement statement and Rule 26(a) Disclosures. Discussion with court clerk and D. Karg regarding postponement of scheduling conference; Discussion with D. Karg regarding scheduling order and settlement issues; Review proposed Scheduling Order and Rule 26 disclosures; Attend Scheduling Conference; Discussion with D. Karg regarding results. Review final Scheduling Order; Docket deadlines. Review and edit Supplemental Computation of Damages forwarded by D. Karg. Review, execute, and arrange for filing and service of Supplemental Computation of Damages.

0.40

07/07/2004

0.90

07/12/2004 07/14/2004 07/20/2004 08/02/2004 08/06/2004

0.10 0.20 0.10 0.50 0.60

08/09/2004

0.80

08/16/2004

2.40

08/18/2004 08/24/2004 08/26/2004

0.20 0.20 0.10

J. Cleveland

G. E. Parish

Date

Detail

C. Krough

D. Scheid

Page 4

Case 1:04-cv-01258-LTB-BNB

Document 151-7

Filed 10/19/2005

Page 6 of 18

Local Counsel's Detailed Time Entries For SMG

I. Walsworth

08/30/2004 09/03/2004 09/08/2004 09/09/2004 09/10/2004

09/14/2004

09/20/2004

10/07/2004

Review Defendant's supplemental calculation of damages. Discussion with D. Karg regarding page limitation on motion to dismiss counterclaim. Review and edit draft Brief in Support of Motion to Dismiss; Transmit comments to D. Karg. Discussion with D. Karg regarding Response to Motion to Dismiss. Review e-mail from D. Karg; Direct research by regarding contract issue requested; Review and edit motion to dismiss; Review final memorandum and motion; Discussion with D. Karg regarding final revisions and results of research; Prepare final revisions and arrange for filing. Discussion with D. Karg (voice-mail) regarding Defendant's response date regarding Motion to Dismiss Counterclaims. Discussion with D. Karg regarding ability to serve written discovery requests regarding counterclaim allegations. Review Defendant's Response to Motion to Dismiss Counterclaim; discussion with D. Karg (voicemail) regarding upcoming settlement conference. Discussion with D. Karg regarding postponement of settlement conference; discussion with M. McElhinney (voicemail) regarding same. Discussion with M. McElhinney and D. Karg regarding postponement of settlement conference. Discussion with D. Karg and M. McElhinney regarding issues related to potential postponement of settlement conference.

0.10 0.10 1.50 0.40 1.40

0.10

0.20

0.40

10/07/2004

0.30

10/11/2004

0.30

10/12/2004

0.90

J. Cleveland

G. E. Parish

Date

Detail

C. Krough

D. Scheid

Page 5

Case 1:04-cv-01258-LTB-BNB

Document 151-7

Filed 10/19/2005

Page 7 of 18

Local Counsel's Detailed Time Entries For SMG

I. Walsworth

10/13/2004

Discussion with D. Karg and M. McElhinney regarding postponement of settlement conference; discussion with court clerk (vm) regarding same; further discussion with D. Karg and M. McElhinney regarding lack of response from court clerk; conference call with M. McElhinney and court clerk to obtain postponement; discussion with D. Karg (vm) regarding results of conference call. Discussion with D. Karg regarding settlement conference rescheduling and substantive issues regarding reply brief. Review draft of Response to Defendant's Reply to Motion to Dismiss. Discussion with T. Alfrey regarding insurance carrier's retention of T. Alfrey to defend counterclaims. Review and edit reply brief; discussion with C. Krogh and D Karg regarding same; arrange for filing and service Review e-mail; discussion with C. Krogh regarding review of discovery requests. Discussion with M. McElhinney regarding request for extension of time regarding expert reports. Review and revise Plaintiff's First Set of Interrogatories Directed To Defendant and Plaintiff's First Request for Production of Documents Directed to Defendant. Discussion with C. Krogh regarding edits to draft discovery requests. Revise Plaintiff's First Set of Interrogatories and Plaintiff's First Set of Requests for Production.

1.10

10/14/2004

0.60

10/19/2004 10/19/2004

0.90 0.30

10/19/2004

1.00

10/28/2004 10/29/2004 11/04/2004

0.20 0.60 0.90

11/04/2004 11/05/2004

0.20 0.70

J. Cleveland

G. E. Parish

Date

Detail

C. Krough

D. Scheid

Page 6

Case 1:04-cv-01258-LTB-BNB

Document 151-7

Filed 10/19/2005

Page 8 of 18

Local Counsel's Detailed Time Entries For SMG

I. Walsworth

11/08/2004

11/08/2004

11/11/2004

Revise First Set of Interrogatories and First Set of Requests For Production; Draft and send email to D. Karg. Review and edit discovery requests; discussion with D. Karg regarding same; discussion with M. McElhinney regarding postponement of settlement conference; finalize and arrange for service of discovery requests. Review CPI motion for extension of time (for expert disclosures) and to vacate settlement conference. Review Minute Order; docket new deadlines. Review CPI's Expert Designation; discussion with D. Karg regarding same. Review correspondence regarding experts and discovery Discussion with D. Karg regarding response to motion for extension of time; review and edit response; arrange for filing and service. Discussion with D. Karg regarding Defendant's failure to provide expert disclosures; review and edit letter to be sent to M. McElhinney; discussion with D. Karg regarding same. Review correspondence to and from opposing counsel regarding expert witness issues; review supplemental expert designation and discovery requests; docket response date. Telephone conference with Judge Babcock's clerk and Gwen Daniel regarding transcript for June 29th hearing.

0.40

1.00

0.10

11/17/2004 12/06/2004 12/13/2004 12/14/2004

0.10 0.30 0.10 0.60

01/05/2005

0.80

01/07/2005

0.30

01/10/2005

0.20

J. Cleveland

G. E. Parish

Date

Detail

C. Krough

D. Scheid

Page 7

Case 1:04-cv-01258-LTB-BNB

Document 151-7

Filed 10/19/2005

Page 9 of 18

Local Counsel's Detailed Time Entries For SMG

I. Walsworth

01/10/2005

01/11/2005

01/12/2005 01/13/2005

01/13/2005

01/14/2005

01/18/2005

01/19/2005

Discussion with D. Karg regarding expert and discovery motions and regarding need to order hearing transcript; discussion with D. Karg to confirm order; further discussion with D. Karg regarding Defendant's indication of purported filing of second motion to extend. Discussion with D. Karg and P. McElhinney regarding discovery and expert designation motions and issues. Review and respond to e-mail regarding negotiations with B. Matise regarding motions. Telephone conference with Magistrate Boland's office regarding Defendant's Second Motion for Extension of Time. Discussion with D. Karg regarding stipulation regarding expert designation deadlines; discussion with C. Krogh and D. Karg regarding discussion with court clerk; review and edit draft stipulation; discussion with D. Karg regarding same; review and respond to e-mail from D. Karg regarding depositions. Review minute order; discussion with D. Karg regarding Confidential Settlement Statement and recent motions. Discussion with D. Karg regarding Confidential Settlement Statement; review draft letter; discussion with D. Karg regarding same; arrange for filing; discussion with court reporter regarding depositions; review pleadings, correspondence, and deposition notices. Discussion with court reporter regarding deposition schedule; discussion with D. Karg regarding deposition dates.

0.90

0.50

0.10 0.20

1.00

0.30

1.30

0.20

J. Cleveland

G. E. Parish

Date

Detail

C. Krough

D. Scheid

Page 8

Case 1:04-cv-01258-LTB-BNB

Document 151-7

Filed 10/19/2005

Page 10 of 18

Local Counsel's Detailed Time Entries For SMG

I. Walsworth

01/21/2005

Review motion for further extension regarding expert disclosures; discussion with D. Karg regarding settlement conference and depositions; discussion with court reporter regarding depositions. Conference with P. McElhinney and J. Stumacher regarding settlement conference. Review e-mail from D. Karg; discussion with C. Krogh regarding status of hearing transcript. Discussion with D. Karg regarding response to motion; review and edit draft motion; prepare e-mail regarding heaping transcript. Telephone call to Hunter & Giest regarding depositions previously set for February 1, 2, 3 and 4th. Discussion with D. Karg regarding postponement of depositions. Discussion with D. Karg regarding stipulation; review stipulation; further discussion with D. Karg regarding same; arrange for filing and service; discussion with court clerk regarding request to vacate hearing; prepare e-mail to D. Karg regarding status; further discussion with court clerk regarding need to attend hearing; discussion with R. Orsini and P. McElhinney (vm) regarding same; prepare confirming e-mails. Telephone conference with Gwen Daniels regarding transcript for June 29th hearing. Attend hearing with Magistrate Judge Boland regarding discovery and scheduling issue. Obtain transcript for June 29th hearing from US District Court. Review order; docket new deadlines.

0.40

01/24/2005 01/25/2005 01/26/2005

0.90 0.10 0.80

01/31/2005

0.10

01/31/2005 02/01/2005

0.20 1.40

02/02/2005 02/02/2005 02/03/2005 02/07/2005

0.10 1.10 0.30 0.10

J. Cleveland

G. E. Parish

Date

Detail

C. Krough

D. Scheid

Page 9

Case 1:04-cv-01258-LTB-BNB

Document 151-7

Filed 10/19/2005

Page 11 of 18

Local Counsel's Detailed Time Entries For SMG

I. Walsworth

03/07/2005 04/11/2005

04/14/2005 04/15/2005

04/15/2005 05/02/2005 05/16/2005

05/17/2005 05/19/2005 05/31/2005

Review e-mail from D. Karg; discussion with D. Karg regarding potential need for Utah subpoena. Discussion with D. Karg regarding summary judgment motion; further discussion with D. Karg regarding potential motion for extension of time. Discussion with D. Karg regarding summary judgment motion. Telephone conference will lead counsel regarding Motion for Summary Judgment and associated documents. Preparation of Unopposed Motion to File Documents Under Seal. Review Motion for Summary Judgment, Memorandum in Support of Motion for Summary Judgment and Cover Sheets for Documents Under Seal. Revise Memorandum in Support of Motion for Summary Judgment and Exhibits and Cover Sheets for Documents Under Seal. Finalize all documents for filing and file with USDC. Discussion with D. Karg regarding summary judgment filing Review and execute Answer to counterclaims; arrange for filing and service. Discussion with D. Karg regarding settlement submission; arrange for delivery to magistrate and service on opposing counsel. Discussion with D. Karg; arrange for filing and service of objection to exhibits. Review and respond to e-mail regarding status of response to Motion for Summary Judgment. Discussion with D. Karg regarding motion to compel filing; arrange for transmittal and copying of necessary attachments; review, execute, and arrange for filing and service.

0.20 0.50

0.20 2.90

0.20 0.20 0.40

0.20 0.20 1.10

J. Cleveland

G. E. Parish

Date

Detail

C. Krough

D. Scheid

Page 10

Case 1:04-cv-01258-LTB-BNB

Document 151-7

Filed 10/19/2005

Page 12 of 18

Local Counsel's Detailed Time Entries For SMG

I. Walsworth

06/03/2005

06/10/2005

06/13/2005 06/14/2005 06/15/2005

06/17/2005

06/20/2005

06/21/2005

06/23/2005 06/24/2005 06/27/2005

Review Judge Boland Order regarding motion to compel briefing schedule and hearing; docket hearing date. Discussion with D. Karg regarding motion to compel hearing, summary judgment response brief, and deposition issues. Review order; docket new hearing date. Discussion with D. Karg regarding motion to strike and regarding J. Grace litigation history. Review and edit motion to strike; discussion with. D. Karg regarding status; review and edit updated draft; arrange for filing and service. Review notice of electronic filing and minute order; discussion with D. Karg's office (T. Long) regarding same; arrange for transmittal of orders. Discussion with D. Karg regarding Minute Order; discussion with G. Parish (vm) regarding status of Defendants service of Summary Judgment response at old firm address. Review e-mail from P. Bates regarding service of pleading on old firm; prepare e-mails to D. Karg regarding same; review additional pleadings and forward to D. Karg. Discussion with D. Karg regarding anticipated filing of motion in limine. Review, execute, and arrange for filing of motion in limine, memorandum brief, and attachments. Review Defendant's response to motion to strike; discussion with D. Karg regarding submittal of expedited reply brief.

0.10

0.30

0.10 0.30 0.60

0.30

0.20

0.50

0.10 0.50 0.30

J. Cleveland

G. E. Parish

Date

Detail

C. Krough

D. Scheid

Page 11

Case 1:04-cv-01258-LTB-BNB

Document 151-7

Filed 10/19/2005

Page 13 of 18

Local Counsel's Detailed Time Entries For SMG

I. Walsworth

06/28/2005

Discussion with D. Karg regarding anticipated filings and July 6 hearing date; review and respond to email regarding hearing; review Minute Order; docket deadlines; review, execute and arrange for filing of responsive pleadings regarding motion in limine and motion for continuance. Discussion with D. Karg regarding hearing and likely issues for Trial Preparation Conference; attend hearing on motion to continuance. Discussion with K. Dugan and D. Karg regarding coordination of communications regarding proposed T. Hiller deposition date; review minute order regarding hearing. Discussion with D. Karg regarding transmittal of pleadings; review minute orders. Discussion with D. Karg regarding reply brief. Review, execute, and arrange for filing of reply brief in support of summary judgment motion. Discussion with D. Karg regarding July 22 hearing. Attend status conference with Judge Babcock regarding Daubert motion hearing. Discussion with D. Karg regarding reply brief in support of motion in limine and need to file entry of appearance; review, execute and arrange for filing of reply brief. Discussion with D. Karg regarding August 17 hearing Review order regarding motion in limine and motion for summary judgment; discussion with D. Karg regarding order and attorneys fee petition deadlines

0.50

07/06/2005

1.40

07/07/2005

0.20

07/11/2005 07/18/2005 07/20/2005 07/21/2005 07/22/2005 07/28/2005

0.10 0.10 0.30 0.10 0.80 0.20

08/16/2005 08/23/2005

0.10 0.50

J. Cleveland

G. E. Parish

Date

Detail

C. Krough

D. Scheid

Page 12

Case 1:04-cv-01258-LTB-BNB

Document 151-7

Filed 10/19/2005

Page 14 of 18

Local Counsel's Detailed Time Entries For SMG

I. Walsworth

08/31/2005

discussion with D. Karg regarding motion for approval of attorneys' fees and supporting affidavits; review draft affidavits; further discussion with D. Karg regarding same. Discussion with D. Karg; review and edit attorneys fee affidavit; update chart regarding fees and costs. Review final attorneys' fee pleadings and affidavits; discussion with D. Karg regarding same; revise order; assemble exhibits; arrange for filing and service. Discussion with D. Karg regarding bill of cost; discussion with G. Parish's office to obtain invoice for service of process. Discussion with D. Karg regarding response to Defendant's forthwith motion to approve bond and stay execution. Review and execute bill of costs; discussion with D. Karg regarding conference with local counsel regarding setting of hearing; arrange for additional information and filing; docket hearing date. Review minute order; discussion with D. Karg's office regarding same. Discussion with court clerk regarding telephone hearing for bill of costs; discussion with D. Karg regarding response to motion to approve bond. Review, assemble and arrange for filing of response to motion to approve bond. Review and transmit appeal pleadings. Review minute order and e-mails from D. Karg and P. McElhinny; discussion with D. Karg regarding same.

0.60

09/01/2005

0.30

09/02/2005

0.80

09/07/2005

0.30

09/08/2005

0.40

09/09/2005 09/12/2005

0.60 0.20

09/13/2005 09/14/2005 09/16/2005

0.20 0.40 0.10

09/19/2005

0.40

J. Cleveland

G. E. Parish

Date

Detail

C. Krough

D. Scheid

Page 13

Case 1:04-cv-01258-LTB-BNB

Document 151-7

Filed 10/19/2005

Page 15 of 18

Local Counsel's Detailed Time Entries For SMG

I. Walsworth

09/20/2005

Review letter from District Court regarding appellate deadlines; discussion with D. Karg regarding same; review, sign, and arrange for filing of supplemental response regarding bond motion; discussion with B. Matisse (vm); discussion with D. Karg regarding same; review 10th Circuit case opening letter; discussion with D. Karg regarding same. Review, execute, and arrange for filing of response to CPI's motion for leave for supplemental filing. Review and transmit order denying motion for approval of bond; discussion with D. Karg regarding same and regarding execution issues. Prepare e-mail to D. Karg regarding 10th Circuit filings; discussion with D. Karg regarding collection on judgments; conference call with D. Karg and J. Stumacher regarding execution issues; discussion with J. Cleveland regarding preparation of necessary garnishments and notice of execution and levy; review additional information forwarded by D. Karg regarding bank accounts and other potential garnishees; forward to J. Cleveland. Research garnishment and attachment procedures and forms for use in federal court.

1.00

09/21/2005

0.10

09/22/2005

0.30

09/26/2005 09/26/2005

1.10 2.40

J. Cleveland

G. E. Parish

Date

Detail

C. Krough

D. Scheid

Page 14

Case 1:04-cv-01258-LTB-BNB

Document 151-7

Filed 10/19/2005

Page 16 of 18

Local Counsel's Detailed Time Entries For SMG

I. Walsworth

09/27/2005

09/27/2005

Discussion with J. Cleveland regarding garnishment and execution forms; review and execute 10th Circuit application; discussion with J. Cleveland and D. Karg regarding local bank and other potential garnishees; review Defendant's Motion to Stay filed with 10th Circuit; discussion with C. Krogh and J. Cleveland regarding execution procedures, timing and bond requirements. Discussions with several local financial institutions regarding accounts they may have for CPI; discussions regarding past account activity, current status and garnishment procedures. Research Federal forms for Writs; phone call with S. Erlich regarding federal process using Writs and need for foreign jurisdiction registration with respect to out-of-state executions; phone call with U.S. Marshall regarding Writ process-their requirements and process; preparation of Garnishment Writs for Colorado banks, preparation of Memo to D. Scheid regarding procedure in federal court for execution against personal assets. Review memo from J. Cleveland regarding garnishments and executions; prepare e-mail to D. Karg regarding same; discussion with D. Karg regarding local bank garnishments; conference call with J. Stumacher and D. Karg regarding same; discussion with J. Cleveland regarding potential garnishees; further discussion with D. Karg regarding execution and 10th Circuit filing issues; review emails regarding bill of costs information.

1.60

J. Cleveland

G. E. Parish

Date

Detail

C. Krough

D. Scheid

0.90

09/27/2005

4.30

09/28/2005

1.50

Page 15

Case 1:04-cv-01258-LTB-BNB

Document 151-7

Filed 10/19/2005

Page 17 of 18

Local Counsel's Detailed Time Entries For SMG

I. Walsworth

09/28/2005

09/29/2005

09/29/2005

Research special filing of Writ to assure speedy service; draft additional Writ to third Colorado Bank; phone call with potential garnishee, phone call with Colorado State Bank, memos and phone calls to D. Scheid and D. Karg. Review e-mails from D. Karg and J. Cleveland; discussion with D. Karg and J. Cleveland regarding garnishments; discussion with process server to confirm service; discussion with D. Karg regarding debtor's exam. Extensive work with Federal Court Clerk to get 3 Writs issued and prepared for immediate service; several calls to Colorado State Bank regarding service and account status. Discussion with J. Stumacher; prepare e-mail to J. Cleveland; review local court rules regarding debtor's exam; discussion with bank representatives regarding status of CPI accounts; discussion with court clerk and Magistrate Boland to set date for debtor's examination; discussions with bank representatives, process server and bank's counsel regarding service of process and freezing of funds; discussion with J. Stumacher and J. Cleveland regarding same; prepare confirming memo to bank's counsel (M. Warczak); review and edit witness and document subpoena for debtor's exam; discussion with 10th Circuit regarding denial of motion for stay; discussion with J. Stumacher and D. Karg regarding same. Obtain rule 69 subpoena form executed by District Court Clerk.

J. Cleveland

G. E. Parish

Date

Detail

C. Krough

D. Scheid

2.50

0.70

3.20

09/30/2005 09/30/2005

3.60 0.50

Page 16

Case 1:04-cv-01258-LTB-BNB

Document 151-7

Filed 10/19/2005

Page 18 of 18

Local Counsel's Detailed Time Entries For SMG

I. Walsworth

09/30/2005

Calls to Colorado State Bank regarding service and accounts status; phone call to client to update, research on "wait period" regarding garnishing bank funds, prepare memo to M. Warczak regarding garnishment; draft list of documents for Rule 69 Subpoena of CPI, Student Marketing Group, Inc.

J. Cleveland

G. E. Parish

Date

Detail

C. Krough

D. Scheid

3.70

Totals

6.70

74.60

1.60

0.50

17.00

Page 17