Free Declaration in Support - District Court of California - California

Case 3:07-cv-04936-CRB

Document 54-2

Filed 03/07/2008

Page 1 of 1

EXHIBIT 1 Summary of Additional Time Spent on APRI v. EPA et. al, No. 07-4936 (N.D. Cal.) Since February 15, 2008 Date 2/15/2008 2/27/2008 Time Spent 1.25 0.75 Task(s) Draft emails to opposing counsel and other defendants' counsel re service of Rule 11 motion; review EPA's motion to dismiss. telephone conversation with W. Sanders re potential arguments re public nuisance claim; research re preemptive effect of Cal. Pub. Res. Code § 25531 on nuisance claim under California law. further work on motion to strike/dismiss; draft proposed order re same; email communications with W. Sanders re supporting documentation. finish drafting motion to strike/motion to dismiss; further work on editing and revising same; review Plaintiffs' opposition to EPA's motion to dismiss. final editing and review of Motion to Strike/Motion to Dismiss; proofread and citecheck same; prepare request for judicial notice; work with C. Forbush re formatting documents for electronic filing; attend to electronic filing of Motion to Strike/Motion to Dismiss and supporting documents; review City of San Francisco motion to dismiss. review sanctions motion; prepare notice of errata re same; draft and edit Second Crockett Declaration; draft proposed order re sanctions motion; work with C. Forbush to prepare documents for electronic filing; attend to electronic filing.

2/28/2008

4.5

2/29/2008

7.5

3/4/2008

8.5

3/7/2008

4

TOTAL:

26.5 hours