Free Motion for Attorney Fees - District Court of Arizona - Arizona

UNITED STATES V. 33.845 ACRES OF LAND CASE NO. CIV-03-2007-PHX-SRB ATTORNEY TIME INCURRED

DATE 1/15/03 1/27/03

ATTY JAW JAW

DESCRIPTION Receipt and review of facsimile from Douglas Wright (split with 192.019 acres). Telephone conference with Bill Waltrip regarding US Navy condemnation (split with 192.019 acres). Receipt and review of Order for delivery of Possession; Receipt and review of Notice of Condemnation; Dictate letter to Sam Perricone; Conference with Glen Curtis and Rocky Curtis; telephone conference to opposing counsel, Susan Klein; Letter to opposing counsel, Susan Klein; Letter to appraiser, Jim Sanders (split with 192.019 acres). Conference with John A. Weil regarding federal condemnation research; Determine federal condemnation statutes (in re: US Navy Department) (split with 192.019 acres). Legal research regarding federal condemnation (split with 192.019 acres). Long distance telephone conference with attorney in Washington DC; Telephone conference with clients, Glen and Rocky Curtis; Long distance telephone conference with Jim Sanders regarding Velda and 14th Street; Review of file; Dictate agreement for access (split with 192.019 acres). Receipt and review of Order for Immediate Possession and Withdrawal of Funds by Terry Goddard (split with 192.019 acres).

HOURS 0.20 0.20

AMOUNT $17.50 $17.50

11/12/03

JAW

3.00

$262.50

11/13/03

LAB

0.60

$37.50

11/14/03 11/18/03

LAB JAW

1.00 3.00

$62.50 $262.50

11/18/03

JAW

0.20

$17.50

Case 2:03-cv-02006-SRB

Document 168-7

Filed 01/30/2007

Page 1 of 27

11/22/03

JAW

8.00 Legal research at law library (Saturday) regarding US Navy v. Curtis/Perricone; Legal research regarding just compensation, federal procedure, deposit, interest, damages, answer, etc (split with 192.019 acres). Dictate Answer; Dictate Demand for Jury Trial; Review of file regarding valuation on Velda, 14th Street and Bend Ranch; Review of file regarding US Navy pleadings; Dictate Notice of Appearance; Legal research regarding possession and withdrawal of deposit (on Sunday) (split with 192.019 acres). Receipt and review of letter by Douglas R. Wright at US Department of Justice regarding US v. Curtis properties (split with 192.019 acres). Conference with Jim Sanders regarding appraisals; Conference with Rocky, Glen, Spike Curtis and Jim Sanders regarding appraisals; trip to view Bend Ranch (split with 192.019 acres). Receipt and review of Notice of Appearance and Claim of Interest by Pat Orozco regarding US v. Curtis (split with 192.019 acres). Receipt and review of letter from Sue Klein regarding US v. Curtis (split with 192.019 acres). Telephone conference with clients Rocky and Glen Curtis; Review of file; Dictate letter to Clifford at USA; Dictate Order (split with 192.019 acres). Receipt and review of Notice to the Court (split with 192.019 acres). Receipt and review of Motion for Withdrawal of Estimated Compensation; Certificate of Service; Notice of Filing Motion for Distribution of Estimated Just Compensation (split with 192.019 acres). 8.00

$700.00

11/23/03

JAW

$700.00

11/24/03

JAW

0.20

$17.50

11/25/03

JAW

4.40

$385.00

12/1/03

JAW

0.20

$17.50

12/5/03

JAW

0.20

$17.50

12/8/03

JAW

1.50

$131.25

12/10/03 12/10/03

JAW JAW

0.20 0.20

$17.50 $17.50

Case 2:03-cv-02006-SRB

Document 168-7

Filed 01/30/2007

Page 2 of 27

12/17/03

JAW

Receipt and review of facsimile from Department of Justice regarding Amended Condition of Title (split with 192.019 acres). Receipt and review of Motion to Transfer Related Cases (split with 192.019 acres). Receipt and review of Order (split with 192.019 acres). Receipt and review of letter with Revised Order for Delivery of Possession from Douglas R. Wright (split with 192.019 acres). Telephone conference with opposing attorney Jim Clark; Review of file; Dictate Objection to Motion to Transfer on 192.019 (Velda) and 33.845 (Bend) cases (split with 192.019 acres). Legal research at University of San Diego (on Friday) regarding release of funds on deposit, Bend/14th Street and Velda (split with 192.019 acres). Review of file; Conference with Jim Clark; Conference with clients Spike, Rocky and Glen Curtis; Review and revision of Motion for Distribution in US Navy cases (split with 192.019 acres). Receipt and review of letter with Plaintiff's Consolidated Response to Defendants' Curtis and Dose's Motion for Withdrawal of Estimated Compensation by Condemnees and Motion for Immediate Distribution on Deposit or Evidentiary Hearing from Mathew S. Clifford (split with 192.019 acres). Receipt and review of offer in compromise on Velda, 14th Street and Bend Ranch (split with 192.019 acres). Telephone conference with clients Rocky and Glen Curtis regarding US Navy lease, settlement, etc. (split with 192.019 acres).

0.20

$17.50

12/19/03 12/19/03 12/22/03

JAW JAW JAW

0.20 0.20 0.20

$17.50 $17.50 $17.50

12/30/03

JAW

1.50

$131.25

1/2/04

JAW

8.00

$700.00

1/6/04

JAW

4.60

$402.50

1/14/04

JAW

0.20

$17.50

1/15/04

JAW

1.30

$113.75

1/15/04

JAW

1.00

$87.50

Case 2:03-cv-02006-SRB

Document 168-7

Filed 01/30/2007

Page 3 of 27

1/16/04

JAW

Telephone conference with Rocky regarding Anel project in Morona, US Navy offer, etc.; Review and revision of U.S. Navy offer; Telephone conference with client Glen Curtis regarding US Navy offer (split with 192.019 acres). Telephone conference with clients Rocky and Glen Curtis regarding US Navy; Long distance telephone conference with Douglas Wright regarding US Navy; Telephone conference with Lori Lineberry (split with 192.019 acres). Conference with Jim Sanders regarding appraisals, comparable sales, etc.; Telephone conference with Bill Waldrip; Telephone conference with client Rocky Curtis regarding citrus expert; Telephone conference with Glen Wright regarding being expert witness (split with 192.019 acres). Proofread second motion for immediate distribution (In re: 33.845 Acres of Land) Telephone conference with John A. Weil regarding rescission of settlement offer; Draft letter for John A. Weil's signature to Douglas Wright rescinding offer; Draft letter to Glen Curtis regarding draft Douglas Wright letter (split with 192.019 acres).

1.50

$131.25

1/19/04

JAW

0.60

$52.50

1/20/04

JAW

2.20

$192.50

1/26/04 1/27/04

LAB LAB

0.30 0.80

$37.50 $50.00

1/29/04

JAW

0.20 Receipt and review of letter dated 1/26/04 regarding response to Defendant Yuma Mesa Irrigation and Drainage District's Request for an Order Requiring Deposit by Matthew S. Clifford (split with 192.019 acres). Receipt and review of letter with United States' response to defendants Curtis and Perricone's Second Motion for Immediate Distribution of Deposit; Revised Order for Delivery of Possession (split with 192.019 acres). 0.10

$17.50

2/2/04

JAW

$8.75

Case 2:03-cv-02006-SRB

Document 168-7

Filed 01/30/2007

Page 4 of 27

2/19/04

JAW

Telephone conference with client Rocky Curtis regarding completion of harvest on Bend, Velda and 14th Street Ranches; Long distance telephone conference with Douglas Wright at US Attorney's Office; Dictate letter to opposing attorney regarding 1 year lease on Velda, Bend and 14th Street Ranches (split with 192.019 acres). Review of file; Long distance telephone conference with Knut (sound expert in Tucson); Conference with Lori Butler regarding US Navy cases; telephone conference with client Glen Curtis regarding status of cases (split with 192.019 acres). Conference with John A. Weil regarding reply memorandum and status of cases; Review files and legal research (split with 192.019 acres). Legal research regarding reply memo in 33 and 192 acres cases; review files regarding the same (split with 192.019 acres). Preparation of reply; Legal research regarding allocation and interest (split with 192.019 acres). Review legal research; Review pleadings; Continue to draft and revise reply in 33.845 Acres. Receipt and review of letter addressed to John A. Weil regarding interim lease proposal by Matthew S. Clifford (split with 192.019 acres). (Saturday) Complete draft of 33.845 Acres. Telephone conference with client Rocky Curtis regarding US Navy Lease; Receipt and review of US Navy Lease Form; Long distance telephone conference with Jim Sanders regarding lease (split with 192.019 acres).

0.50

$43.75

2/23/04

JAW

0.40

$35.00

2/23/04

LAB

1.50

$93.75

2/24/04

LAB

3.80

$237.50

2/25/04

LAB

2.90

$181.25

2/27/04

LAB

5.80

$725.00

2/27/04

JAW

0.20

$17.50

2/28/04 3/1/04

LAB JAW

2.30 0.50

$287.50 $43.75

Case 2:03-cv-02006-SRB

Document 168-7

Filed 01/30/2007

Page 5 of 27

3/2/04

JAW

Receipt and review of letter from Matthew S. Clifford regarding leasing of the properties (split with 192.019 acres)..

0.20

$17.50

3/3/04

JAW

1.50 Review and revision of Motion for Disbursement of Funds on US Navy v. Bend, 14th Street and Velda Ranches; Conference with Lori Butler; Telephone conference with client Rocky Curtis regarding status; Telephone conference with Doug Hipp regarding easement on 6E (split with 192.019 acres). Redraft Replies in Federal Condemnation cases; Review all documents to confirm review of all cases cited by Plaintiff and Yuma Mesa Irrigation and Drainage District (split with 192.019 acres). Conference with John A. Weil regarding Reply in 33.845 acres of land and Reply in 192.019 acres of land; Review government documents regarding bids to lease all property; Review Reply in 192.019 acres of land (split with 192.019 acres). Review and revision of Memorandum on Distribution of Deposit; Dictate letter to Rocky Curtis; Dictate letter to opposing attorney Matt Clifford regarding US Navy v. Bend, 14th Street and Velda Ranches (split with 192.019 acres). Legal research to find cases involving Yuma Mesa Irrigation and Drainage District and property rights as compared to landowners; Revise Reply in 33.845 acres of land; Revise Reply in 192.019 acres of land; Conference with John A. Weil regarding both Replies; Draft letter to Clerk of Court for filing and to Judge Bolton regarding Replies (split with 192.019 acres). Receipt and review of letter from Matthew Clifford regarding Rule 26(f) Conference (split with 192.019 acres). 4.50

$131.25

3/3/04

LAB

$281.25

3/4/04

LAB

5.00

$312.50

3/5/04

JAW

1.00

$87.50

3/5/04

LAB

5.00

$312.50

3/24/04

JAW

0.20

$17.50

Case 2:03-cv-02006-SRB

Document 168-7

Filed 01/30/2007

Page 6 of 27

3/25/04

LAB

Draft Reply to Plaintiff's Response on Supplemental Memorandum; Draft letters to Clerk of Court regarding filing (split with 192.019 acres). Draft Reply to YMIDD's Response to Supplemental Memorandum; telephone conference with Spike Curtis and Rocky Curtis regarding distribution of deposit in Department of Navy cases (split with 192.019 acres). Receipt and review of letter from Matthew S. Clifford (split with 192.019 acres). Review of file; Preparation for Hearing Motion for Disbursement of Funds (Sunday) (split with 192.019 acres). Appearance at Court on Motion to Disburse; Deliver checks (USN) to Rocky and ChaCha; Telephone conference with client Glen Curtis regarding status, etc. (split with 192.019 acres). Telephone conference with Jim Sanders regarding appraisal of property and appointment; Prepare memorandum on work to be done prior to trial (split with 192.019 acres). Conference with Jim Sanders and Craig Horn regarding APZ-1, ARS Section 488481, et seq.; Conference with Lori Butler regarding APZ maps, counts ordinance, etc.; Dictate memorandum (split with 192.019 acres). Draft memorandum on Rule 26 Conference and matters for joint discovery plan; Review rules, court order and files (split with 192.019 acres). Receipt and review of letter with enclosed Plaintiff's Initial Disclosures (split with 192.019 acres).

4.60

$287.50

3/29/04

LAB

1.80

$112.50

4/7/04 4/11/04

JAW JAW

0.20 2.00

$17.50 $175.00

4/12/04

JAW

2.00

$175.00

5/3/04

LAB

0.80

$50.00

5/4/04

JAW

1.00

$87.50

5/4/04

LAB

3.50

$218.75

5/5/04

JAW

0.20

$17.50

Case 2:03-cv-02006-SRB

Document 168-7

Filed 01/30/2007

Page 7 of 27

5/5/04

LAB

Complete memo regarding Rule 26 Conference; Review maps with John A. Weil; Telephone conference with Roger Patterson at Yuma County DDS to obtain new APZ1 and APZ2 maps (split with 192.019 acres). Obtain current zoning regulations and land use plan for Yuma County; Review maps for APZ1 and APZ2 and clear zones pertinent to property; Review file and documents received from government regarding land use (split with 192.019 acres). Receipt and review of lettre from Matthew S. Clifford (split with 192.019 acres). Conference with John A. Weil regarding pretrial conference; Revise answers to amended complaints (split with 192.019 acres). Review of file; Conference with Lori Butler; Appearance at Pretrial Conference; Long distance telephone conference with Damian Fellows; Telephone conference with client Rocky Curtis (split with 192.019 acres).

3.50

$218.75

5/7/04

LAB

3.50

$218.75

5/10/04 5/10/04

JAW LAB

0.20 0.40

$17.50 $25.00

5/11/04

JAW

1.20

$105.00

5/11/04

LAB

0.90 Telephone conference with all counsel for Rule 26 Conference; Conference with John A. Weil regarding Rule 26 Conference; Telephone conference with John A. Weil and Damian Fellows (split with 192.019 acres). 0.20 Receipt and review of original and two copies of disclaimer of interest received from Defendant Yuma County Citrus Pest Control District and Defendant Yuma County Pest Abatement District by Matthew S. Clifford (In re: 33.845 Acres of land). Receipt and review of Motion to Continue Pretrial Conference; Receipt and review of joint proposed case management plan; Begin draft Defendant's Initial Disclosure Statement (split with 192.019 acres). 1.20

$56.25

5/18/04

LAB

$25.00

5/25/04

LAB

$75.00

Case 2:03-cv-02006-SRB

Document 168-7

Filed 01/30/2007

Page 8 of 27

5/26/04

LAB

Draft Disclosure Statement in both Department of Navy cases (split with 192.019 acres). Research regarding Yuma County Regulation and City of Yuma Regulations in Airport Zones (split with 192.019 acres). Receipt and review of letter with Order from A. James Clark (split with 192.019 acres). Receipt and review of Plaintiff's Response to Defendant YMIDD's Motion to Continue Rule 16 Pretrial Scheduling Conference by Matthew S. Clifford (split with 192.019 acres). Draft Curtis Defendants' additions to Proposed Case Management Plan; Draft Defendants Curtis' Response to Motion to Reschedule Scheduling Conference (split with 192.019 acres). Conference with Tom Parsons and Damian Fellows; Review file; View property and conference with clients Glen and Rocky Curtis, Tom and Damian regarding condemnation action; Dictate Notice of Association of Counsel (split with 192.019 acres). View property and conference with Tom Parsons and Damian Fellows (split with 192.019 acres). Receipt and review of Notice of Withdrawal of Motion to Continue Rule 16 Scheduling Conference by A. James Clark (split with 192.019 acres).

3.00

$187.50

5/28/04

LAB

0.80

$50.00

6/1/04 6/1/04

JAW JAW

0.20 0.20

$17.50 $17.50

6/7/04

LAB

3.50

$218.75

6/8/04

JAW

2.00

$175.00

6/8/04

JAW

1.80

$157.50

6/10/04

JAW

0.20

$17.50

Case 2:03-cv-02006-SRB

Document 168-7

Filed 01/30/2007

Page 9 of 27

6/14/04

JAW

Review of file; Legal Research on right to jury trial; Travel to Phoenix for case management conference; Conference with Tom Parsons; Conference with opposing attorney Jim Clark YMIDD; Conference with opposing attorney Sue Klein; Appearance at Court; Return to Yuma, calendar all deadlines; Conference with Lori Butler (split with 192.019 acres). Conference with Larry Schubert and Damian Fellows; Review of file regarding sound issues; Conference with Jim Sanders regarding appraisals deadlines, etc. (split with 192.019 acres). Conference with Larry Schubert and Damian Fellows regarding US Navy issues, APZ Zone, Probability of rezoning, citrus prices, industrial property, etc.; Conference with clients Rocky, Spike and John Curtis, Larry Schubert, Damian Fellows etc. at Curtis office (split with 192.019 acres). Receipt and review of First Notice of Discovery and Settlement addressed to Judge R. Bolton from Stubbs & Schubert, PC (split with 192.019 acres). Receipt and review of Plaintiff's first set of interrogatories to Yuma Mesa Irrigation and Drainage District (split with 192.019 acres). Review file regarding appraisals and government offer (split with 192.019 acres). Review Jim Sanders' appraisals on the Bend and the 14th Street properties (split with 192.019 acres). Review all documents produced by government in 192.019 acres and 33.845 acres (Bates Nos. 0001 to 1514); Review federal district court docket and compare all documents in file for complete file (split with 192.019 acres).

4.00

$350.00

7/27/04

JAW

1.50

$131.25

7/27/04

JAW

3.00

$262.50

9/13/04

LAB

0.10

$6.25

1/24/05

LAB

0.20

$12.50

3/2/05 3/3/05

LAB LAB

0.50 2.20

$37.50 $165.00

3/21/05

LAB

5.20

$390.00

Case 2:03-cv-02006-SRB

Document 168-7

Filed 01/30/2007

Page 10 of 27

4/7/05

LAB

Receipt and review of correspondence regarding extensions to deadlines for rebuttal reports and supplements to discovery; Receipt and review of First Supplemental Disclosure Statement for In re: 192 Acres concerning APZ zones (split with 192.019 acres). Receipt and review of Jim Sanders' Narrative Appraisal Memorandum (split with 192.019 acres). Receipt and review of First Supplemental Disclosure Statement in In Re: 192.019 Acres and In Re: 33.845 Acres (split with 192.019 acres). Telephone conference with Damian Fellows regarding YMIDD settlement and future actions to obtain deposit held at court; Review District Court website regarding YMIDD cases and settlements in cases (split with 192.019 acres). Receipt and review of Jim Sanders' file as turned over to Department of Justice; Prepare index to file (In re: 192.019 Acres and In re: 33.845 Acres); Receipt and review of two facsimiles from Glen Curtis regarding subpoenas received by Spike and Rocky Curtis; Draft letter to Damian Fellows regarding subpoenas (split with 192.019 acres). Receipt and review of facsimile letter from Damian Fellows regarding depositions (split with 192.019 acres). Telephone conference with Spike Curtis regarding subpoenas received; Telephone conference with Damian Fellows regarding subpoenas; Receipt and review of Interrogatories and Request for Production (split with 192.019 acres).

0.90

$67.50

4/12/05

LAB

0.40

$30.00

4/18/05

LAB

0.70

$52.50

4/21/05

LAB

0.40

$30.00

4/25/05

LAB

2.50

$187.50

4/26/05

LAB

0.10

$7.50

4/27/05

LAB

0.70

$52.50

Case 2:03-cv-02006-SRB

Document 168-7

Filed 01/30/2007

Page 11 of 27

6/2/05

LAB

Receipt and review of facsimile from Matt Clifford and Doug Wright; Telephone conference with John A. Weil; Telephone conference with Damian Fellows; Review files; Prepare memorandum on discovery status, witnesses, exhibits, maps and appraisers (split with 192.019 acres). Review of file; Analysis of Dorchester appraisal; Analysis of Dorchester comparable sales properties; Outline things to complete for trial preparation (on Saturday) (split with 192.019 acres). (On Sunday) Read Joint Land Use Plan; Legal research Yuma County Zoning Ordinance regarding APZ zones; Legal research regarding Heavy Industrial Zoning; Legal research regarding validating of Dorchester methodology (split with 192.019 acres). Study Sanders' appraisal on Velda; Trip in Jeep to Mesa area to inspect properties listed as comparable sales (split with 192.019 acres). Review files regarding accident potential zones; Review maps; Talk to planner at Zoning Commission to obtain Yuma County Noise Contours Map (split with 192.019 acres). Conference with John A. Weil; Review Dorchester appraisals, zoning ordinances, materials relied on by Dorchester; maps relied on by Dorchester (split with 192.019 acres). Telephone conference with Jim Sanders regarding appraisals, meeting, APZ zones, methodology, etc. (split with 192.019 acres). Review legislation for accident potential zones; Review Joint Land Use Plan and zoning ordinances for compliance in zoning of properties (split with 192.019 acres).

2.60

$195.00

6/11/05

JAW

6.00

$675.00

6/12/05

JAW

3.50

$393.75

6/13/05

JAW

3.80

$427.50

6/13/05

LAB

3.00

$225.00

6/14/05

LAB

0.50

$37.50

6/15/05

JAW

1.00

$112.50

6/15/05

LAB

1.40

$105.00

Case 2:03-cv-02006-SRB

Document 168-7

Filed 01/30/2007

Page 12 of 27

6/17/05

JAW

Conference with Damian Fellows and Jim Sanders in Tucson regarding status of case, discovery deadlines, etc. (split with 192.019 acres). Legal research regarding accident potential zones and enacting of ordinances adopting them (split with 192.019 acres). Telephone conference with Ginger Hamilton at Yuma County Board of Supervisors regarding ordinances and APZs; Telephone conference with Rocky Curtis regarding date of rezoning of Velda and Bend; Receipt and review of petition for hearing to rezone (split with 192.019 acres). Telephone conference with Bob Woodman regarding citrus sales; Telephone conference with Mark Spencer; Telephone conference with Hector Hurtado; Long distance telephone conference with Doug Wright; Telephone conference with Jim Sanders regarding acreages, etc.; Receipt and review of District Court Judge (split with 192.019 acres). Review of file; Conference with Mark Spencer; Conference with Bob Woodman; Conference with clients Rocky and Spike Curtis; Dictate answers to interrogatories; Dictate response to motion to produce; Telephone conference with Bob Tuffly; Telephoned numerous people regarding comparable sales (split with 192.019 acres). Receipt and review of Orders Disbursing Funds to YMIDD under settlement agreement; Calculate funds at Court registry; Draft memo to John A. Weil regarding funds; Draft two joint motions to extend discovery deadline and two proposed orders; Go to Planning and Zoning to obtain rezoning file for the Bend ranch; Review zoning file; Review rezoning board minutes to locate rezoning information (split with 192.019 acres).

1.00

$112.50

6/17/05

LAB

2.50

$187.50

6/20/05

LAB

0.60

$45.00

6/21/05

JAW

2.80

$315.00

6/22/05

JAW

5.50

$618.75

6/22/05

LAB

1.40

$105.00

Case 2:03-cv-02006-SRB

Document 168-7

Filed 01/30/2007

Page 13 of 27

6/22/05

LAB

Go to Planning and Zoning to obtain rezoning file for the Bend Ranch; Review zoning file; Review rezoning board minutes to locate rezoning information (split with 192.019 acres). Review file and Dorchester's appraisal citing runway approach areas; Legal research regarding runway approach areas and airport districts and effect on the three ranches (split with 192.019 acres). Review/revise response to interrogatories and response to motion to produce prepared by John A. Weil in US v. 192 Acres; Telephone conference with John A. Weil regarding 33 Acres; Review files; Draft response to interrogatories and response to motion to produce in US v. 33 Acres (split with 192.019 acres). (Saturday) Revise response to interrogatories iin US v. 33.845 Acres of land. Conference with Jim Sanders; Review and revision of answers to interrogatories; Conference with Jim Sanders and Spike Curtis (split with 192.019 acres). Telephone conference with Ginger Hamilton at Yuma County Board of Supervisors; Receipt and review of memo from Ginger Hamilton regarding adoption of ordinances; Review Zoning Ordinances including Land Use Matrix and inapplicability of runway approach areas; Begin draft of interoffice memorandum on APZs and effect on rezoning (split with 192.019 acres). Revise memorandum on APZs, runway approach areas, airport districts and effect on rezoning of the Velda, Bend and 14th Street Ranches (split with 192.019 acres).

2.40

$180.00

6/23/05

LAB

2.20

$165.00

6/24/05

LAB

5.00

$375.00

6/25/05 6/27/05

LAB JAW

2.00 3.20

$300.00 $360.00

6/27/05

LAB

4.50

$337.50

6/29/05

LAB

5.00

$375.00

Case 2:03-cv-02006-SRB

Document 168-7

Filed 01/30/2007

Page 14 of 27

6/30/05

JAW

Preparation of request for production; Preparation of interrogatories; Preparation of request for admissions; Dictate letter to opposing attorney Doug Wright; Long distance telephone conference with Jim Sanders (split with 192.019 acres). Draft memorandum on accident potential zones (APZs), RADSA and potential for rezoning for properties (split with 192.019 acres). Telephone conference with client Rocky Curtis regarding records; Long distance telephone conference with Doug Wright and Damian Fellows; Dictate letter to opposing attorney regarding documents produced; Receipt and review of loan file (split with 192.019 acres).

2.50

$281.25

6/30/05

LAB

4.50

$337.50

7/8/05

JAW

1.60

$180.00

7/13/05

JAW

1.00 Telephone conference with client Cha Cha regarding documents on comparable sales; Telephone conference with client Spike Curtis; Dictate supplement to interrogatories; Review and revision of revised reports from Sanders; Long distance telephone conference with Jim Sanders (split with 192.019 acres). Conference with client Spike Curtis; Receipt and review of documents from Cha Cha; Dictate supplemental responses to interrogatories 6, Conference with Spike Curtis on interrogatories 14 and 22 regarding discovery (split with 192.019 acres). Conference with John A. Weil regarding remaining deposit at Court and actions to obtain withdrawal (split with 192.019 acres). Review file regarding reasons Department of Justice and Court denied release of full deposit; Draft letter to Doug Wright and Matt Clifford regarding distribution of remaining deposit; Draft order and stipulation for release (split with 192.019 acres). 1.00

$112.50

7/14/05

JAW

$112.50

7/29/05

LAB

0.20

$15.00

8/3/05

LAB

3.50

$262.50

Case 2:03-cv-02006-SRB

Document 168-7

Filed 01/30/2007

Page 15 of 27

8/3/05

LAB

Review Dorchester website and obtain articles and presentations cited on website; Review articles and presentations and draft memo to John A. Weil regarding findings (split with 192.019 acres). Legal research regarding admission and timing of comparable sales for purposes of evidence at deposition and trial (split with 192.019 acres). Conference with Spike and Rocky Curtis regarding US Navy v. 33.845 Acres; Preparation for deposition of Glen T. Curtis; Preparation for deposition of Robert O. Curtis. Draft memorandum on owner's right to testify and opinion on valuation (split with 192.019 acres). Additional legal research on timing of comparable sales and owner's right to testify thereto; Revise memorandum regarding same; Draft motion for withdrawal of remainder of deposit by condemnees (split with 192.019 acres). Continued legal research on timing of comparable sales (post-taking) and owner's right to testify regarding post-taking sales; Revise memorandum regarding same (split with 192.019 acres). G-12, US Navy condemnation on Bend Ranch; Review of file; Preparation for Deposition of Jim Sanders; Conference with Jim Sanders and Damian Fellows in Tucson (split with 192.019 acres). G-12,US Navy, Bend: Appearance at Jim Sanders deposition in Tucson; Conference with Spike Curtis (split with 192.019 acres).

2.50

$187.50

8/4/05

LAB

4.50

$337.50

8/15/05

JAW

3.00

$675.00

8/25/05

LAB

3.80

$285.00

8/26/05

LAB

4.00

$300.00

8/29/05

LAB

3.20

$240.00

8/30/05

JAW

8.00

$900.00

8/31/05

JAW

8.00

$900.00

Case 2:03-cv-02006-SRB

Document 168-7

Filed 01/30/2007

Page 16 of 27

9/6/05

LAB

Complete revisions to memorandum on owner's right to testify to comparable sales and timing of sales; Interoffice conference regarding subpoena for Tom Manfredi; Obtain District Court subpoena from District Court (split with 192.019 acres). Review of file; Preparation for Deposition of Tom Manfredi; Prepare exhibits; Appearance at deposition of Tom Manfredi; Telephone conference with clients Spike and Rocky Curtis regarding deposition G-12Bend (½) and Perricone/Curtis for 14th Street and Velda (½) (split with 192.019 acres). Conference with Jim Sanders; Review recent rules; Review changes to deposition (split with 192.019 acres). Draft Proposed Order and Motion for Distribution of Accrued Interest on Deposit in US v. 192.019 Acres of Land; Draft Proposed Order and Motion for Distribution of Accrued Interest on Deposit in US v. 33.845 Acres of Land; Draft two electronic mail messages to Judge Bolton with Proposed Orders and Motions (split with 192.019 acres). Review of file; Dictate motion to extend discovery date; Dictate letter to opposing attorney Sue Klein. (split with 192.019 acres).

1.70

$127.50

9/8/05

JAW

10.50

$1,181.25

9/27/05

JAW

2.50

$281.25

11/4/05

LAB

2.50

$187.50

11/9/05

JAW

0.50

$56.25

12/5/05

JAW

Long distance telephone conference with Sue 1.00 Klein; Long distance telephone conference with Jim Sanders; Telephone conference with client Spike Curtis; Preparation for hearing Amended Notice of Deposition (split with 192.019 acres). Telephone conference with Kathy McCloud regarding tax identification numbers; Telephone conference with Dana at District Court Finance Department regarding delivery of funds (split with 192.019 acres). 0.30

$112.50

12/13/05

LAB

$22.50

Case 2:03-cv-02006-SRB

Document 168-7

Filed 01/30/2007

Page 17 of 27

12/23/05

JAW

Telephone conference with opposing attorney Sue Klein regarding Order Modifying Schedule (split with 192.019 acres). Telephone conference with Brian at McMillin regarding irrigation ditches; Telephone conference with client Spike Curtis regarding depositions; Long distance telephone conference with Jim Sanders regarding depositions (split with 192.019 acres). Review of file; Long distance telephone conference with Jim Sanders regarding updates on U.S. Navy cases (split with 192.019 acres). Two long distance telephone conferences with Sue Klein; Two long distance telephone conferences with Jim Sanders regarding Bend, 14th Street and Velda Ranches (split with 192.019 acres). Preparation for depositions of Jim Sanders (split with 192.019 acres). Review all DVDs in file; Review Dorchester's working file DVDs for documents for deposition including impeachment material; Prepare notebooks of contents of DVDs (split with 192.019 acres). Preparation for Deposition of John Dorchester (Bend/Velda/14th Street Ranches) (split with 192.019 acres). Review remaining John Dorchester working file DVDs for documents providing impeachment material; Prepare notebooks of contents of DVDs (Saturday) (split with 192.019 acres). Preparation for deposition of John Dorchester (Saturday) (split with 192.019 acres).

0.50

$56.25

1/25/06

JAW

0.80

$90.00

2/10/06

JAW

1.00

$112.50

3/6/06

JAW

1.00

$112.50

3/16/06 3/17/06

JAW LAB

8.00 5.30

$900.00 $397.50

3/17/06

JAW

8.00

$900.00

3/18/06

LAB

7.30

$547.50

3/18/06

JAW

6.00

$675.00

Case 2:03-cv-02006-SRB

Document 168-7

Filed 01/30/2007

Page 18 of 27

3/19/06

JAW

Preparation for deposition of John Dorchester (Sunday) (split with 192.019 acres). Prepare exhibits; Conference with Jim Sanders in Phoenix; Preparation for deposition of Jim Sanders (split with 192.019 acres). Appearance at deposition of Jim Sanders; Conference with Jim Sanders; Preparation for deposition of John Dorchester (split with 192.019 acres). Appearance at deposition of John Dorchester (split with 192.019 acres). Preparation for deposition of John Dorchester (split with 192.019 acres). Conference with client Spike Curtis regarding preparation for his deposition (split with 192.019 acres). Telephone conference with Robby Barkley regarding comparable sale, etc. (split with 192.019 acres). Conference with client Spike Curtis regarding deposition; Attend meeting at MCAS (split with 192.019 acres). Preparation for deposition of Spike Curtis in US Navy cases; Revise and prepare comparable sale summaries, etc. (split with 192.019 acres). Attend Spike Curtis depositions in US Navy cases (split with 192.019 acres). Conference with client and Jim Sanders; Review new comparables; Dictate three letters to opposing attorney Sue Klein; US Navy conference (split with 192.019 acres). Dictate Settlement Conference statements US v. 33.845 Acres of Land case.

8.00

$900.00

3/20/06

JAW

10.00

$1,125.00

3/21/06

JAW

10.00

$1,125.00

3/22/06 3/23/06 3/23/06

JAW JAW JAW

10.00 10.00 2.00

$1,125.00 $1,125.00 $225.00

3/30/06

JAW

0.50

$56.25

3/31/06

JAW

8.00

$900.00

4/3/06

JAW

4.50

$506.25

4/4/06 4/5/06

JAW JAW

8.00 4.00

$900.00 $450.00

5/1/06

JAW

4.00

$900.00

Case 2:03-cv-02006-SRB

Document 168-7

Filed 01/30/2007

Page 19 of 27

7/5/06

JAW

Review of file; Conference with Lori Butler; Preparation for trial and pretrial statements (split with 192.019 acres). Legal research regarding voir dire and condemnation blight jury instruction and federal procedures for trial (split with 192.019 acres). Conference with John A. Weil regarding motions in limine; Legal research regarding motion in limine; Draft motion in limine to exclude evidence of defendant's wealth or ownership in other entities in both bases (split with 192.019 acres). Conference with John A. Weil regarding additional motions in limine; Review file; Draft motion in limine to exclude Revised Appraisal Report in 192.019 Acres; Draft motion in limine to exclude Revised Appraisal Report in 33.845 Acres; Revise motions in limine to exclude evidence of defendant's financial status; Review filing requirements of joint pretrial order (split with 192.019 acres). Review of file; Read appraisals; Organize exhibits; Dictate draft joint pretrial statement (US Navy) (split with 192.019 acres). Revise motions in limine; Legal research regarding appraisal report submitted after Court discovery deadline; Draft motions in limine to exclude Revised Appraisal Report of John Dorchester (Saturday) (split with 192.019 acres). Review of file; Long distance telephone conference with Sue Klein; Telephone conference with Monty Stansbury; Conference with Lori Butler (US Navy) (split with 192.019 acres).

6.00

$675.00

7/5/06

LAB

1.00

$75.00

7/6/06

LAB

7.50

$562.50

7/7/06

LAB

8.50

$637.50

7/8/06

JAW

8.00

$900.00

7/8/06

LAB

5.00

$375.00

7/10/06

JAW

5.50

$618.75

Case 2:03-cv-02006-SRB

Document 168-7

Filed 01/30/2007

Page 20 of 27

7/10/06

LAB

Telephone conference with John A. Weil regarding motions in limine; Review docket and download motions in limine (US Navy) (split with 192.019 acres). Review of file; Two long distance telephone conferences with Jim Sanders; Review Dorchester deposition; Long distance telephone conference with Tony regarding video assistance (US Navy) (split with 192.019 acres). Legal research regarding motions in limine; Draft response to motion in limine to exclude offers of purchase of property (split with 192.019 acres). US Navy; Complete jury questionnaire, voir dire questions, and jury instructions (split with 192.019 acres).

1.00

$75.00

7/11/06

JAW

7.00

$787.50

7/11/06

LAB

8.80

$660.00

7/12/06

JAW

8.00

$900.00

7/12/06

LAB

3.00 Draft response to motion in limine to exclude prices paid for similar property in US v. 192.019 Acres of Land; Draft response to motion in limine to exclude prices paid for similar property in US v. 33.845 Acres of Land (split with 192.019 acres). Review of file; Preparation of response on motion to exclude evidence of Dune Company sale; Legal research at law library; Dictate response (US Navy) (split with 192.019 acres). Review of file; Preparation for interviews; Conference with Monty Stansbury; Conference with Maggie Carrasco; Conference with Anne Eichberger; Read Jim Sanders deposition (split with 192.019 acres). Trip to University of San Diego Law Library; Legal research regarding Daubert cases; Legal research regarding regression analysis (US Navy) (split with 192.019 acres). 10.00

$225.00

7/13/06

JAW

$1,125.00

7/14/06

JAW

8.00

$900.00

7/15/06

JAW

9.00

$1,012.50

Case 2:03-cv-02006-SRB

Document 168-7

Filed 01/30/2007

Page 21 of 27

7/16/06

JAW

Dictate response to motion to exclude Jim Sanders report on Daubert case; Long distance telephone conference with Jim Sanders (Sunday) (US Navy) (split with 192.019 acres). Review exhibit list; Review and revision of joint pretrial order; Four long distance telephone conferences with Sue Klein; Conference on jury instructions (US Navy) (split with 192.019 acres). Read Dorchester deposition; Review of file; Legal research on sales to US Navy (Woodman/Martin Ranches); Dictate responses to motion in limine on sale to government (US Navy) (split with 192.019 acres). Review of file; Read Dorchester deposition; Outline impeachment strategies; Review and revision of responses on motion in limine; Receipt and review of government responses; Legal research (split with 192.019 acres). Review of file; Legal research at ASU Law Library in Phoenix on motions in limine (US Navy) (split with 192.019 acres). Appearance at Court pretrial conference in Phoenix, AZ; Conference with opposing attorney Sue Klein; Long distance telephone conference with Jim Sanders regarding trial date, etc.; Conference with Lori Butler; Dictate letter to all witnesses regarding new trial date; Conference with Paul at Graphic Law regarding docket preparation (US Navy) (split with 192.019 acres).

9.00

$1,012.50

7/17/06

JAW

8.00

$900.00

7/18/06

JAW

8.00

$900.00

7/19/06

JAW

10.00

$1,125.00

7/22/06

JAW

8.00

$900.00

7/24/06

JAW

8.00

$900.00

7/26/06

JAW

8.00 Long distance telephone conference with Glen Curtis regarding railroad; Telephone conference with client Rocky Curtis regarding railroad; Review of file; Read Tom Manfredi deposition; Outline questions. (split with 192.019 acres).

$900.00

Case 2:03-cv-02006-SRB

Document 168-7

Filed 01/30/2007

Page 22 of 27

7/28/06

JAW

Telephone conference with client Rocky Curtis regarding railroad; Review of file; Outline questions for deposition and trial (split with 192.019 acres). Review of file; Read pleadings and attorney notes; Preparation for deposition of Maggie Carrasco (Saturday) (US Navy) (split with 192.019 acres). Review of file; Preparation of questions for Tom Manfredi; View industrial areas (on Sunday) (US Navy) (split with 192.019 acres). Trial preparation; Review all exhibits; Preparation of trial exhibits (split with 192.019 acres). Trial preparation; Preparation for witnesses, Spencer and Woodman examinations (split with 192.019 acres). Meeting with witnesses Spencer and Woodman to prepare for trial; Trial preparation (split with 192.019 acres). Legal research regarding admissibility of hearsay evidence on comparable sales used by expert witness (split with 192.019 acres). Meeting with witness/client to prepare for trial; Trial preparation; Trip to court with Spike Curtis; Conference with Spike Curtis (split with 192.019 acres). Trial preparation; Research and review all potential legal issues; Outline case theory and progression; Preparation for objections on both sides (split with 192.019 acres). Meeting with exhibit expert in Phoenix (Paul Steele); Review exhibits; Discuss trial strategy, review witness and exhibit sequence (split with 192.019 acres).

8.00

$900.00

7/29/06

JAW

8.00

$900.00

7/29/06

JAW

8.00

$900.00

7/30/06

JAW

10.00

$1,125.00

7/31/06

JAW

8.00

$900.00

8/1/06

JAW

12.00

$1,350.00

8/1/06

LAB

5.50

$412.50

8/2/06

JAW

12.00

$1,350.00

8/3/06

JAW

12.00

$1,350.00

8/4/06

JAW

10.00

$1,125.00

Case 2:03-cv-02006-SRB

Document 168-7

Filed 01/30/2007

Page 23 of 27

8/4/06

LAB

Legal research regarding hearsay evidence of comparable sales; Draft memorandum regarding admissibility of hearsay evidence of comparable sales used by expert witness for appraisal (split with 192.019 acres). Trial preparation, further preparation of trial exhibits; Preparation of juror examination, jury instructions, examination of witnesses, cross examination of government's witnesses, opening and closing statements (split with 192.019 acres).

5.80

$435.00

8/5/06

JAW

12.00

$1,350.00

8/6/06

JAW

12.00 Trial preparation, including preparation of trial exhibits; Preparation of juror examination, jury instructions, examination of witnesses, cross examination of government's witnesses, opening and closing statements (split with 192.019 acres). Trial preparation; Preparation for depositions of Lori Lineberry and Maggie Carasco (split with 192.019 acres). Legal research for memorandum on admissibility of hearsay evidence used by expert witness; Revise memorandum on admissibility of hearsay evidence used by expert witness; Review exhibits for trial; Conference with John A. Weil regarding additional legal research required (split with 192.019 acres). Trial preparation; Deposition of Lori Lineberry; Deposition of Maggie Carasco (split with 192.019 acres). Review exhibits and exhibit list for trial (split with 192.019 acres). Legal research regarding admissibility of comparable sales through testimony of nonexpert witness; Review exhibit lists and exhibits for trial (split with 192.019 acres). 10.00

$1,350.00

8/7/06

JAW

$1,125.00

8/7/06

LAB

4.50

$337.50

8/8/06

JAW

12.00

$1,350.00

8/8/06 8/8/06

LAB LAB

2.80 4.50

$210.00 $337.50

Case 2:03-cv-02006-SRB

Document 168-7

Filed 01/30/2007

Page 24 of 27

8/9/06

JAW

12.00 Trial preparation, including preparation of trial exhibits; Preparation of juror examination, jury instructions, examination of witnesses, cross examination of government's witnesses, opening and closing statements (split with 192.019 acres). 4.00 Legal research regarding admissibility of evidence of wealth of defendants; Draft supplemental memorandum regarding wealth of defendants (split with 192.019 acres). 12.00 Trial preparation, including preparation of trial exhibits; Preparation of jury examination, jury instructions, examination of witnesses, cross examination of government's witnesses, opening and closing statements (split with 192.019 acres). Review exhibit lists and exhibits for trial (split with 192.019 acres). Trial preparation, conference with Spike Curtis; Preparation of juror examination, jury instructions, examination of witnesses, cross examination of government's witnesses, opening and closing statements (split with 192.019 acres). Draft memorandum on admissibility of comparable sales through testimony of nonexpert witness (split with 192.019 acres). 3.00 12.00

$1,350.00

8/9/06

LAB

$300.00

8/10/06

JAW

$1,350.00

8/10/06 8/11/06

LAB JAW

$225.00 $1,350.00

8/11/06

LAB

3.50

$262.50

8/12/06

JAW

12.00 Trial preparation, including preparation of trial exhibits; Preparation of juror examination, jury instructions, examination of witnesses, cross examination of government's witnesses, opening and closing statements (split with 192.019 acres). 12.00 Trial preparation, including preparation of trial exhibits; Preparation of juror examination, jury instructions, examination of witnesses, cross examination of government's witnesses, opening and closing statements (split with 192.019 acres).

$1,350.00

8/13/06

JAW

$1,350.00

Case 2:03-cv-02006-SRB

Document 168-7

Filed 01/30/2007

Page 25 of 27

8/14/06 8/15/06 8/16/06 8/17/06 8/18/06 8/22/06

JAW JAW JAW JAW JAW LAB

Travel to Phoenix; Meet with witnesses; Trial preparation (split with 192.019 acres). Conduct trial; Preparation for next day's trial events (split with 192.019 acres). Conduct trial; Preparation for next day's trial events (split with 192.019 acres). Conduct trial; Preparation for next day's trial events (split with 192.019 acres). Conclusion of trial; Return to Yuma (split with 192.019 acres). Receipt and review of e-mail from Sue Klein; Telephone conferences with Kathy regarding principal balance due on judgment; Review file and orders and calculate principal balance due; Draft letter to Sue Klein regarding same (split with 192.019 acres). Telephone conference with Sue Klein regarding judgment and payment; Receipt and review of e-mail regarding proposed judgments; Draft e-mail to Sue Klein; Receipt and review of letter from Sue Klein regarding interest (split with 192.019 acres). Receipt and review of e-mail from the District Court regarding proposed judgments (split with 192.019 acres).

12.00 12.00 12.00 12.00 11.00 1.20

$1,350.00 $1,350.00 $1,350.00 $1,350.00 $1,237.50 $90.00

8/23/06

LAB

.60

$45.00

8/24/06

LAB

0.10

$7.50

8/28/06

LAB

0.20 Telephone conference with John A. Weil regarding legal research and memorandum to obtain additional interest on verdict (split with 192.019 acres). Legal research regarding additional interest to be added to judgment to compensate for government's delay in distribution of deposit; Legal research regarding recovery of costs in condemnation action (split with 192.019 acres). 3.50

$15.00

9/6/06

LAB

$262.50

Case 2:03-cv-02006-SRB

Document 168-7

Filed 01/30/2007

Page 26 of 27

9/7/06

LAB

Legal research regarding Equal Access to Justice Act and potential to recover costs and/or attorney's fees (split with 192.019 acres). Review files and pleadings regarding prior motions to obtain distribution of deposits throughout case; Begin drafting objection to proposed form of judgment (split with 192.019 acres). Review file; Draft Defendants' Objection to Proposed Form of Judgment (In re: 33.845 Acres of land). Receipt and review of government response to objection to form of Judgment; Conference with Lori Butler (In re: 33.845 Acres of land). Total Time:

4.50

$337.50

9/8/06

LAB

3.50

$262.50

9/12/06

LAB

2.00

$300.00

9/26/06

JAW

1.70

$382.50

$86,747.75

Case 2:03-cv-02006-SRB

Document 168-7

Filed 01/30/2007

Page 27 of 27