Free Appendix - District Court of Delaware - Delaware

CONTRACT ATTORNEY TIME SHEET:

MARSHA E. FLORA
July 20 ,

2006

DATE
(HRS)

Case 1:04-cv-00163-GMS

CLIENT NUMBER

MATTER NUMBER
DESCRIPTION

TIME

7/20/06
L400
L430
A103

3514

L440

A104

Review and analyze David Athey deposition and exhibits thereto in preparation of trial
Draft detailed statement of uncontested facts with citations as required by the pre trial order

Document 309-23

7/20/06
L400

3514

Filed 10/25/2006 Page 1 of 25

~~~~

CONTRACT ATTORNEY TIME SHEET:

MASHA E. FLORA
July 21

2006

Case 1:04-cv-00163-GMS

CLIENT NUMBER

MATTER NUMBER
DESCRIPTION

Acm1T
I PHASE I TASK I
1.0

7/21/06
A101

3514

L400

L440

Prepare submissions for pre trial order; strategy for trial presentation

Document 309-23

7/21/06
L400
A103

3514
L430

Draft detailed statement of uncontested facts with citations as required by the pre trial order

Filed 10/25/2006 Page 2 of 25

CONTRACT ATTORNEY TIME SHEET:

MASHA E. FLORA
July 22 , 2006

DATE
PHASE
(HRS)

Case 1:04-cv-00163-GMS

CLIENT NUMBER
12.
A 103

MATTER NUMBER
TASK
ACTIVITY

TIME
DESCRIPTION

7/22/06
L400
L430

3514

Draft detailed statement of uncontested facts with citations as required by the pre trial order

Document 309-23 Filed 10/25/2006 Page 3 of 25

CONTRACT ATTORNEY TIME SHEET:

MARSHA E. FLORA
July 23, 2006

TIME
DESCRIPTION
(HRS)

Case 1:04-cv-00163-GMS

CLIENT NUMBER

MATTER NUMBER

TY I

I PHASE I TASK I ACTl
11.3

7/23/06

3514

L400
A103

L430

Draft detailed statement of uncontested facts with citations as required by the pre trial order

Document 309-23 Filed 10/25/2006 Page 4 of 25

CONTRACT ATTORNEY TIME SHEET:

MARSHA E. FLORA
July 24, 2006

DATE
(HRS)

Case 1:04-cv-00163-GMS

CLIENT MATTER NUMBER NUMBER

TIME
DESCRIPTION

AcrWIT
I PHASE I TASK II

7/24/06

3514

L400' L420
A104

Review and analyze Dr, Mar s May 31 , 2006 expert report and attachments; Review and analyze Dr. Richardson s May 31
2006 expert report and attachments; Review and analyze Dr.

Document 309-23

Richardson s March 11 2004 expert report and attachments; Review and analyze Dr. Richardson s January 2004 expert report and attchments; Review and analyze URS' January 30 2004 expert report and attachments;
L400
L440

7/24/06

3514

A104

Review fie , pleadings , documents produced and depositions

regarding Durkin s claims of interference with prospective and existing contractual relationships
L400
L440
A103

Filed 10/25/2006

7/24/06

3514

Review of documents produced and prepare detailed chronological list of documents produced in preparation for trial

Page 5 of 25

CONTRACT ATTORNEY TIME SHEET:

MASHA E. FLORA
July 25, 2006 .

TIME
PHASE

TASK
DESCRIPTION

Case 1:04-cv-00163-GMS

CLIENT MATTER NUMBER NUMBER
(HRS)

7/25/06
L440

3514

L400

A104

Research fie regarding facts in support of spoliation of as builts; review discovery requests and responses regarding as builts; review correspondence regarding requests for as builts; Review depositions regarding as built sureys
Prepare submissions for pre trial order; strategy for trial presentation

Document 309-23

7/25/06 L400
A101

3514

L440

7/25/06
L400
L440
A103

3514

Review of documents produced and prepare detailed chronological list of documents produced in preparation for trial

Filed 10/25/2006 Page 6 of 25

CONTRACT ATTORNEY TIME SHEET:

MASHA E. FLORA
July 26

2006

DATE
PHASE

TIME
TASK
ACTIVITY
DESCRIPTION
(HRS)

Case 1:04-cv-00163-GMS

CLIENT NUMBER

MATTER NUMBER

7/26/06

3514

L400

L440

A104

Review depositions regarding council packets; Review documents produced by the City regarding council packets; review fie , correspondence and depositions for exhibits for certification in support of rule 37(b) Motion; review deposition requests for council packets

Document 309-23

7/26/06
L400

3514

L440

A104

Review and analyze documents produced by the City in preparation for drafting exhibit list as required by the Pre Trial Order
Review of documents produced and prepare detailed chronological list of documents produced in preparation for trial

Filed 10/25/2006

7/26/06
1.6

3514
L400
A103

L440

Page 7 of 25

CONTRACT ATTORNEY TIME SHEET:

MASHA E. FLORA
July 27, 2006

DATE
PHASE

CLIENT NUMBER
DESCRIPTION
(HRS)

MATTER NUMBER

TIME

Case 1:04-cv-00163-GMS

I TASK I ACTlVITY

7/27/06
L400
A103

3514

L430

Document 309-23

7/27/06
L400

3514

L440

A104

Draft Motion for sanctions under Federal Rule of Civil Procedure 37(d) relating to David J, Athey s Production of Briefing Packets ; Draft Memorandum of Law in support of Motion for sanctions under Federal Rule of Civil Procedure 37(d) relating to David J, Athey s Production of " Briefing Packets ; prepare proposed order; prepare exhibits for appendix for Motion for sanctions under Federal Rule of Civil Procedure 37(d) relating to David J, Athey s Production of " Briefing Packets ; review discovery requests regarding briefing packets; draft certification of counsel in support of Rule 3 7(b) motion for sanctions Review and analyze documents produced by the City in preparation for drafting exhibit list as required by the Pre Trial Order

Filed 10/25/2006

7/27/06
1.8

3514

L400

L440

A 103

Review of documents produced and prepare detailed chronological list of documents produced in preparation for trial
A102
Conduct research regarding Rule 3 7
(b)

7/27/06
L400

3514

L440

sanctions; review cases
regarding same

Page 8 of 25

CONTRACT ATTORNEY TIME SHEET:

MASHA E. FLORA
July 28, 2006

DATE
(HRS)

Case 1:04-cv-00163-GMS

CLIENT NUMBER

MATTER NUMBER

TIME

DESCRIPTION

7/28/06

3514

I PHASE I TASK I AcTlVITY A103 Draft Motion to preclude the City from arguing or attempting to L400 L430
present evidence that a date other than November 21 2003 was

Document 309-23

7/28/06

3514

L400
L440

A104

the date upon which the City believes that it provided prior notice of its intention to terminate Durkin as required under the Contract; Draft Memorandum of Law in support of Motion to preclude the City form arguing or attempting to present evidence that a date other than November 21 2003 was the date upon which the City believes that it provided prior notice of its intention to terminate Durkin as required under the Contract; prepare proposed order; prepare exhibits for appendix; review pleadings and prior court submissions regarding same Review and analyze documents produced by URS in preparation for drafting exhibit list as required by the Pre Trial Order
Review of documents produced and prepare detailed chronological list of documents produced in preparation for trial

Filed 10/25/2006

7/28/06
1.4

3514

L400

L440

A103

Page 9 of 25

7/28/06
1.5

3514

L400

L440

A102

Conduct research regarding judicial estoppel; review cases regarding same

CONTRACT ATTORNEY TIME SHEET:

MARSHA E. FLORA
July 29 , 2006

Case 1:04-cv-00163-GMS

CLIENT MATTER NUMBER NUMBER
DESCRIPTION
(HRS)

TIME
I PHASE

AcTMTY I

7/29/06 L400
L440
A 104

3514

Review and analyze documents produced by City in preparation for drafting exhibit list as required by the Pre Trial Order
Review and analyze documents produced by Craig Calabria in preparation for drafting exhibit list as required by the Pre Trial Order Review of documents produced and prepare detailed chronological list of documents produced in preparation for trial
Conduct research regarding spoliation; review cases regarding same

7/29/06 L400
L440

3514

A104

Document 309-23

7/29/06 L400
L440
A103

3514

Filed 10/25/2006

7/29/06 L400
A 102

3514

L440

Page 10 of 25

CONTRACT ATTORNEY TIME SHEET:

MARSHA E. FLORA
J uly 30 2006

Case 1:04-cv-00163-GMS

DATE
I Tu

CLIENT NUMBER

MATTER NUMBER
DESCRIPTION

AcrVITV I
~ I PHASE I TASK I

7/30/06
L400

3514

L440

A104

Research file. regarding facts for spoliation of URS documents by Glenn Bowen; review discovery requests and responses for URS documents; review correspondence for exhibits for spoliation of URS documents; review depositions for requests for URS documents

Document 309-23

7/30/06
L430
A103

3514

L400

7/30/06
L400
A101

3514

L440

Draft Motion for relief from intentional destruction of " briefing packets " and other information provided to the City Council; Draft Memorandum in support of Motion for relief from intentional destruction of "briefing packets " and other information provided to the City Council; draft proposed order; compile appendix for Motion Prepare submissions for pre trial order; strategy for trial presentation

Filed 10/25/2006

7/30/06
1.3

3514

L400

L440

A104

Review and analyze exhbits attched to depositions

Page 11 of 25

CONTRACT ATTORNEY TIME SHEET:

MARSHA E. FLORA
August 31

2006

DATE
(HRS)

Case 1:04-cv-00163-GMS

CLIENT NUMBER

MATTER NUMBER
PHASE

TIME
TASK
ACTIVITY
DESCRIPTION

8/31/06
A101

3514
L400
L430

L400
L430

Document 309-23

8/31/06

3514

A102

Prepare for pre trial conference by reviewing and analyzing joint submissions and motions in limine Review and analyze case law in preparation of pre trial conference

Filed 10/25/2006 Page 12 of 25

CONTRACT ATTORNEY TIME SHEET:

MARSHA E. FLORA
August 1, 2006

Case 1:04-cv-00163-GMS

CLIENT NUMBER
DESCRIPTION

MATTER NUMBER

PHASE I TASK I AcTIVITV

I ~~~~ I
L400
L440

8/1/06

3514

A104
A103

Review and analyze documents produced by the City in preparation for submission of Pre Trial Order

8/1/06

3514

L400

L430

Document 309-23

8/1/06
L400
A101

3514

L440

Draft Motion for bifurcation of liability and damages phases of the trial; Draft Memorandum in support of Motion for bifucation of liability and damages phases of the trial; draft . proposed order; compile appendix for Motion Prepare submissions for pre trial order; strategy for trial presentation
Conduct research regarding Rule 41 and cases in Delaware where bifurcation has been permitted

Filed 10/25/2006

8/1/06
L400

3514

L430

A102

Page 13 of 25

CONTRACT ATTORNEY TIME SHEET:

MASHA E. FLORA
August 2 , 2006

DATE
PHASE
(HRS)

Case 1:04-cv-00163-GMS

CLIENT NUMBER
TASK
DESCRIPTION

MATTER NUMBER

TIME
ACTIVITY

8/2/06
A103

3514
L400 L430

Document 309-23

Draft Motion to preclude the City from offering evidence or argument that the method for paying for incomplete work under the contract is a different method than what the Rule 30(b)(6) witness indicated; Draft Memorandum in support of Motion to preclude the City from offering evidence or argument that the method for paying for incomplete work under the contract is a different method than what the Rule 30(b)(6) witness indicated; compile appendix for Motion
Review and prepare appendices for all Motions in Limine Conduct research regarding contractual provisions that indicate incomplete work is to be made on time and materials basis including review of contract and all submitted pay applications for a determination of incomplete work
Review and analyze documents produced by Calabria prior to
his deposition

8/2/06

3514
L430
A103

L400
L400
L430

Filed 10/25/2006

8/2/06

3514

A102.

8/2/06

3514
L440

L400

A104

Page 14 of 25

~~:

CONTRACT ATTORNEY TIME SHEET:

MASHA E. FLORA
Augst 3 , 2006

Case 1:04-cv-00163-GMS

DATE
DESCRIPTION
II PHASE II TASK II

CLIENT NUMBER

MATTER NUMBER

AcTfVIY I
6.5

8/3/06
L400

3514

L430
A103

Document 309-23

Draft Motion to preclude the City from asserting a joint defense privilege between the City and URS corporation and Motion for an Order directing the City to immediately produce any documents that are being withheld on the basis of joint defense privilege; Draft Memorandum in support of Motion to preclude the City from asserting a joint defense privilege between the City and URS corporation and Motion for an Order directing the City to immediately produce any documents that are being withheld on the basis of joint defense privilege; compile appendix for Motion
Review fie , pleadings ,

8/3/06
1.6

3514

L400
L430
A103

Filed 10/25/2006

8/3/06

3514

L400

L430

A102

briefs and responses to motions and depositions regarding claim of joint defense between the City and URS Conduct research joint defense privilege; review cases regarding same
A104

8/3/06

3514

L400

L440

Prepare submissions for pre trial order; strategy for trial presentation

Page 15 of 25

CONTRACT ATTORNEY TIME SHEET:

MARSHA E. FLORA
August 4, 2006

DATE
(HRS)

Case 1:04-cv-00163-GMS

CLIENT NUMBER

MATTER NUMBER
PHASE

TIME

DESCRIPTION

8/4/06

3514

L400

L430

A103

Draft Motion for relief from intentional destruction of official backup field documentation generated by URS Corporation; Draft Memorandum in support of Motion for relief from intentional destruction of official backup field documentation generated by URS Corporation; compile appendix for Motion

Document 309-23

8/4/06
1.5

3514
L400

L400 L410
A104

L430

AlO2

8/4/06

3514

Conduct research regarding punitive damage claims under Section 1983; review of cases regarding same Review daily reports from URS and other documents produced by URS

Filed 10/25/2006 Page 16 of 25

CONTRACT ATTORNEY TIME SHEET:

MARSHA E. FLORA

Augst 5, 2006

DATE
AcTWITY

TIME
PHASE
(HRS) 12.1

Case 1:04-cv-00163-GMS

CLIENT NUMBER

MATTER NUMBER

TASK

DESCRIPTION

8/5/06

3514

L400

L430
A103

Draft detailed exhibit list as required by the Pre Trial Order
Document 309-23 Filed 10/25/2006 Page 17 of 25

CONTRACT ATTORNEY TIME SHEET:

MARSHA E. FLORA
August 6, 2006

DATE
PHASE

TIME
TASK
DESCRIPTION

ACTIVITY

Case 1:04-cv-00163-GMS

CLIENT NUMBER
(HRS)

MATTER NUMBER

8/6/06
6.3

3514

L400
A103

L430

Draft Motion to preclude evidence to Durkin s bid on the Reservoir Project; Draft Memorandum in support of Motion to preclude evidence to Durkin s bid on the Reservoir Project; compile appendix for Motion

Document 309-23

8/6/06

3514

L400 L430

A102

Filed 10/25/2006

8/6/06

3514

L400

L430

A104

Conduct research regarding the need for an estimator expert to discuss the bid; review of cases regarding same; Conduct research regarding need for expert testimony; review cases regarding same; Conduct research regarding Rule 702; review of cases regarding same Review of fie and deposition testimony regarding Durkin s bid

Page 18 of 25

CONTRACT ATTORNEY TIME5HEET:

MARSHA E. FLORA
Augst 7 , 2006

DATE
PHASE
(HRS)

CLIENT NUMBER

MATTER NUMBER
TASK
ACTIVITY

TIME
DESCRIPTION

Case 1:04-cv-00163-GMS

8/7/06

3514

L400
A103

L430

Document 309-23

Draft Motion to preclude the City from presenting evidence of trespass including alleged interference with construction activities and evidence of Michael D, Durkin and James W, Durkin being arested for criminal trespass at the Newark Reservoir; Draft Memorandum in support of Motion to preclude the City from presenting evidence of trespass including alleged interference with construction activities and evidence of Michael D. Durkin and James W. Durkin being arested for criminal trespass at the Newark Reservoir; compile appendix for Motion; draft proposed order

8/7/06

3514

L400 L400 L430

L430

A102 A104

8/7/06

3514

Conduct research regarding Rule 403; review cases regarding same Review of fie and deposition testimony regarding the arests of the Durkins for trespass

Filed 10/25/2006

8/7/06
1.5

3514

L400

L430

A 104

Review and analyze protective order fied by the City of Newark regarding trespass; Review and analyze Durkin response to same; review police report regarding same; Review and analyze certification of James and Michael Durkin regarding same
L440
A103

Page 19 of 25

8/7/06

3514

L400

Prepare detailed exhibit list; review documents produced regarding same

CONTRACT ATTORNEY TIME SHEET:

MARSHA E. FLORA
Augst 8 , 2006

DATE

CLIENT NUMBER

MATTER NUMBER

TIME
PHASE

TASK
DESCRIPTION

ACTIVITY

(HRS)

Case 1:04-cv-00163-GMS

8/8/06
A103

3514
L400 L430

Draft Motion to preclude URS from offering any testimony based on scientific , technical or other specialized knowledge within the scope of Rule 702; Draft Memorandum in support of Motion to preclude URS from offering any testimony based on scientific , technical or other specialized knowledge within the scope of Rule 702; compile appendix for Motion; draft proposed order

Document 309-23

8/8/06
L400

3514

L430

A102

8/8/06

3514

L400
L440
A103

Conduct research regarding Rule 702; review cases regarding same; review Delaware recent cases regarding need to produce experts; Conduct research regarding experts who are employees of defendant and requirements to naming such experts Prepare detailed exhibit list; review documents produced regarding same
Review fie ,

Filed 10/25/2006

8/8/06

3514
L400 L430

A104

discovery and court submissions regarding submission of experts

Page 20 of 25

CONTRACT ATTORNEY TIME SHEET:

MARSHA E. FLORA
August 9 , 2006

DATE
PHASE
(HRS)

CLIENT NUMBER
TASK
ACTIVITY
DESCRIPTION

MATTER NUMBER

TIME

Case 1:04-cv-00163-GMS

8/9/06

3514
A103

L400

L440

Prepare detailed exhibit list; review documents produced regarding same Draft jury instructions as required by Pre Trial Order
Review and analyze documents produced by URS

8/9/06
A 103

3514
L400 L400

L430 L440

Document 309-23

8/9/06

3514

A104

Filed 10/25/2006 Page 21 of 25

CONTRACT ATTORNEY TIME SHEET:

MARSHA E. FLORA
August 10 , 2006

CLIENT NUMBER
(HRS)

MATTER NUMBER

PHASE i TASK ACTIVITY
DESCRIPTION

I TWE I
L400 L440
A103

Case 1:04-cv-00163-GMS

8/1 0/06

3514
L400
A103

Prepare detailed exhibit list; review documents produced regarding same
Draft jur instructions as required by Pre Trial Order

8/1 0/06

3514

L430
L430

Document 309-23

8/1 0/06

3514

L400

A102

Conduct research regarding jury instructions for Section 1983 conspiracy and defamation

Filed 10/25/2006 Page 22 of 25

CONTRACT ATTORNEY TIME SHEET:

MASHA E. FLORA
August 11 ,

2006
DESCRIPTION

DATE
PHASE
(HRS)

CLIENT NUMBER
TASK
ACTIVITY

MATTER NUMBER

TIME

Case 1:04-cv-00163-GMS

8/11106

3514
5.5

L400
A103

L440
L430
A103

Prepare detailed exhibit list; review documents produced regarding same

8/11/06

3514

L400

Document 309-23

8/11106
1.2

3514

L400

L430

A102

Draft jury instructions for: seven day notice under the contract section 1983 for Council members , section 1983 for City of Newark , spoliation ofURS documents , spoliation of "briefing packets , bifurcation Conduct research regarding notice under construction contracts; review cases regarding same

Filed 10/25/2006 Page 23 of 25

CONTRACT ATTORNEY TIME SHEET:

MASHA E. FLORA
August 12 ,

2006
DESCRIPTION

DATE

CLIENT NUMBER

MATTER NUMBER

TIME
PHASE
(HRS)

Case 1:04-cv-00163-GMS

8/12/06
L400
A 104

3514

L440

Review and analyze George and Lunch daily reports

Document 309-23 Filed 10/25/2006 Page 24 of 25

CONTRACT ATTORNEY TIME SHEET:

MARSHA E. FLORA
August 13 ,

2006
DESCRIPTION

DATE
PHASE
(HRS)

CLIENT NUMBER

MATTER NUMBER
TASK
ACTIVITY

TIME

Case 1:04-cv-00163-GMS

8/13/06

3514

L400
L440

A104

Review and analyze expert reports , file , discovery, documents produced regarding contested facts for the trial brief; obtain citations for same

Document 309-23

8/13/06
A103

3514

L400

L430

Draft trial brief

Filed 10/25/2006 Page 25 of 25