Case 20-10343-LSS Doc 1137 Filed 08/21/20 Page 1 of 10
IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE
Chapter 11 In re: Case No. 20-10343 (LSS) BOY SCOUTS OF AMERICA AND 1 DELAWARE BSA, LLC, (Jointly Administered)
Debtors. Objection Deadline: September 4, 2020 at 4:00 p.m. (ET)
SUMMARY COVER SHEET OF FIFTH MONTHLY APPLICATION OF OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C. FOR ALLOWANCE OF COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR THE PERIOD FROM JULY 1, 2020 TO AND INCLUDING JULY 31, 2020
Name of Applicant: Ogletree, Deakins, Nash, Smoak & Stewart, P.C.
Authorized to Provide Professional Services to: Debtors and Debtors in Possession
Date of Retention: February 18, 2020
Period for Which Compensation and Reimbursement Are Requested: July 1, 2020 – July 31, 2020
Amount of Compensation Requested: $109,544.68 (80% of $136,930.85)2
Amount of Compensation Requested from $6,930.00 Insurers:
Amount of Expense Reimbursement Requested: $81.19
Amount of Expense Reimbursement Requested $0.00 from Insurers:
This is a(n): monthly x interim final application
1 The Debtors in these chapter 11 cases, together with the last four digits of each Debtor’s federal tax identification number, are as follows: Boy Scouts of America (6300) and Delaware BSA, LLC (4311). The Debtors’ mailing address is 1325 West Walnut Hill Lane, Irving, Texas 75038. 2 The amount of compensation and fees requested does not include fees and expenses to be paid directly to Ogletree Deakins by one or more insurance carriers in certain non-abuse claims or cases. While Ogletree Deakins reserves the right to seek future payment from the Debtors for such claims and cases, at this time Ogletree Deakins is not seeking payment from the Debtors on these claims and cases.
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PRIOR MONTHLY APPLICATIONS FILED
Requested Approved Outstanding Date Period Filed; Fees Expenses Fees Expenses Fees Expenses Covered Docket No. February 4/29/2020; 18, 2020 – Docket No. $393,030.80 $1,923.42 $314,424.64 $1,923.42 $34.20 $0 March 31, 512 2020 April 1, 5/28/2020; 2020 – Docket No. $146,042.10 $128.96 $116,833.68 $128.96 $0 $0 April 30, 717 2020 May 1, 6/18/2020; 2020 – Docket No. $128,646.50 $627.81 $102,917.20 $627.81 $102,917.20 $627.81 May 31, 867 2020 June 1, 7/22/2020; 2020 – Docket No. $133,225.40 $81.19 $106,580.32 $81.19 $106,580.32 $81.19 June 30, 1037 2020
COMPENSATION AND HOURS BY PROFESSIONAL
Year of Position Admission Hourly Total Total Name Area of / Years of Rate Hours3 Compensation Expertise Experience Bruce A. Griggs Shareholder 1989 / 31 $640.00 53.5 $34,240.00 Gavin Martinson Shareholder 2005 / 15 $440.00 5.9 $2,442.60 Charles E. McDonald, III Shareholder 1995 / 25 $460.00 1.1 $470.25 Ronald W. Chapman Shareholder 1995 / 25 $650.00 0.7 $453.60 James R. Silvers Shareholder 2009 / 11 $435.00 0.7 $274.05 J. Allen Thomas Shareholder 2009 / 11 $410.00 0.4 $147.60 Sean E. Manning Of Counsel 2001 / 19 $425.00 157.1 $69,909.50 Gretchen W. Ewalt Of Counsel 1983 / 37 $515.00 0.7 $337.05 Gustavo Suarez Of Counsel 2003 / 17 $440.00 0.3 $124.20 Kelci A. Davis Paralegal N/A $190.00 146.3 $27,797.00 Katie Murray Other N/A $150.00 3.7 $555.00 Malia Crane Other N/A $250.00 0.8 $180.00 Total 371.2 $136,930.85
3 Ogletree, Deakins, Nash, Smoak & Stewart, P.C. charged the Debtors for 50% of non-working travel time in compliance with Local Rule 2016-2(d)(viii). Such reductions are reflected in the figures in this column.
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COMPENSATION AND EXPENSES BY PROJECT CATEGORY
Task Description Total Hours Total Compensation
Litigation/Claims / Phase 1 348.6 $128,721.85 Retention Issues / Phase 2 22.6 $8,209.00 Plan Issues / Phase 3 0 $0 Non-working Travel / Phase 4 0 $0 TOTAL 371.2 $136,930.85
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EXPENSES BY CATEGORY
Category Amount Legal Support Services $81.19 TOTAL: $81.19
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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE
Chapter 11 In re: Case No. 20-10343 (LSS) BOY SCOUTS OF AMERICA AND 1 DELAWARE BSA, LLC, (Jointly Administered)
Debtors. Objection Deadline: September 4, 2020 at 4:00 p.m. (ET)
FIFTH MONTHLY APPLICATION OF OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C. FOR ALLOWANCE OF COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR THE PERIOD FROM JULY 1, 2020 TO JULY 31, 2020
Ogletree, Deakins, Nash, Smoak & Stewart, P.C. (“Ogletree Deakins”), special litigation
counsel for the Boy Scouts of America and Delaware BSA, LLC, the non-profit corporations that
are debtors and debtors in possession (together, the “Debtors”) in the above-captioned chapter 11
cases, hereby submits this second monthly application (this “Application”) requesting payment in
the aggregate amount of $109,544.68, which is equal to (a) 80% of the $136,930.85 of total
compensation earned by Ogletree Deakins for its services to the Debtors during the period from
July 1, 2020 to and including July 31, 2020 (the “Fee Period”) and (b) 100% of the $81.19 of
necessary expenses incurred by Ogletree Deakins during the Fee Period in connection with its
services to the Debtors.2 In support of this Application, Ogletree Deakins respectfully represents
as follows:
1The Debtors in these chapter 11 cases, together with the last four digits of each Debtor’s federal tax identification number, are as follows: Boy Scouts of America (6300) and Delaware BSA, LLC (4311). The Debtors’ mailing address is 1325 West Walnut Hill Lane, Irving, Texas 75038. 2 The amount of compensation and fees requested does not include fees and expenses to be paid directly to Ogletree Deakins by one or more insurance carriers in certain non-abuse claims or cases. While Ogletree Deakins reserves the right to seek future payment from the Debtors for such claims and cases, at this time Ogletree Deakins is not seeking payment from the Debtors on these claims and cases.
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JURISDICTION AND VENUE
1. The United States Bankruptcy Court for the District of Delaware (the “Court”) has
jurisdiction over this matter pursuant to 28 U.S.C. § 1334 and the Amended Standing Order of
Reference from the United States District Court for the District of Delaware, dated February 29,
2012. This matter is a core proceeding within the meaning of 28 U.S.C. § 157(b)(2). Venue is
proper in this district pursuant to 28 U.S.C. §§ 1408 and 1409.
2. The statutory and other bases for the relief requested herein are sections 330 and
331 of chapter 11 of title 11 of the United States Code, 11 U.S.C. §§ 101–1532 (the “Bankruptcy
Code”), rule 2016 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), rule
2016-2 of the Local Rules of Bankruptcy Practice and Procedure of the United States Bankruptcy
Court for the District of Delaware (the “Local Rules”), and the Order (I) Approving Procedures
for (A) Interim Compensation and Reimbursement of Expenses of Retained Professionals and
(B) Expense Reimbursement for Official Committee Members and (II) Granting Related Relief
[Docket No. 341] (the “Compensation Procedures Order”).
BACKGROUND
3. On February 18, 2020 (the “Petition Date”), each of the Debtors filed a voluntary
petition with the Court for relief under chapter 11 of the Bankruptcy Code. The Debtors continue
to operate and maintain their non-profit organization and manage their properties as debtors in
possession pursuant to sections 1107(a) and 1108 of the Bankruptcy Code. On February 19, 2020,
the Court entered an order [Docket No. 61] authorizing the joint administration and procedural
consolidation of the chapter 11 cases pursuant to Bankruptcy Rule 1015(b).
4. The Debtors retained Ogletree Deakins as their special litigation counsel, nunc pro
tunc to the Petition Date, pursuant to the Order Authorizing the Retention and Employment of
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Ogletree, Deakins, Nash, Smoak & Stewart, P.C. as Special Litigation Counsel for the Debtors and Debtors in Possession, Nunc Pro Tunc to the Petition Date [Docket No. 364] (the “Retention
Order”). The Retention Order authorizes the Debtors to compensate and reimburse Ogletree
Deakins in accordance with the terms and conditions set forth in the Debtors’ application to retain
Ogletree Deakins, subject to Ogletree Deakins’ application to the Court.
5. On April 6, 2020, the Court entered the Compensation Procedures Order. The
Compensation Procedures Order provides, among other things, that each professional shall be
entitled, on or as soon as practicable after the fifteenth (15th) day of each month following the
month for which compensation and/or expense reimbursement is sought, to file and serve an
application for interim allowance of compensation earned and reimbursement of expenses incurred
during the preceding month (each a “Monthly Fee Application”). Parties shall have fourteen (14)
days after service of a Monthly Fee Application to file an objection to the compensation or
expenses that are the subject thereof (the “Objection Deadline”). Upon the expiration of the
Objection Deadline, the applicant may file a certificate of no objection (a “CNO”) with the Court
with respect to the unopposed portion of the fees and/or expenses requested in the applicable
Monthly Fee Application. After the filing of a CNO, the Debtors are authorized and directed to
pay the applicant an amount equal to 80% of the fees and 100% of the expenses requested in the
applicable Monthly Fee Application not subject to an objection.
RELIEF REQUESTED
6. By this Application, in accordance with the Compensation Procedures Order,
Ogletree Deakins requests payment in the aggregate amount of $109,544.68, which is equal to
(a) 80% of the $136,930.85 of total compensation earned by Ogletree Deakins during the Fee
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Period for its services to the Debtors and (b) 100% of the $81.19 of necessary expenses incurred by Ogletree Deakins during the Fee Period in connection with its services to the Debtors.
SUMMARY OF SERVICES RENDERED
7. Attached hereto as Exhibit A is a detailed statement of the time expended and compensation earned by Ogletree Deakins during the Fee Period with respect to Phase 1 tasks
(Litigation/Claims). Attached hereto as Exhibit B is a detailed statement of the time expended and compensation earned by Ogletree Deakins during the Fee Period with respect to Phase 2 tasks
(Retention Issues). Ogletree Deakins’ professionals expended a total of 371.2 hours in connection with these chapter 11 cases during the Fee Period. All services for which Ogletree Deakins is requesting compensation were performed for or on behalf of the Debtors. The services rendered by Ogletree Deakins during the Fee Period are categorized as set forth in Exhibit A and in the summary cover sheets prefixed to this Application. The professionals who provided services to the Debtors during the Fee Period are also identified in Exhibit A and in the summary cover sheets.
ACTUAL AND NECESSARY EXPENSES
8. Ogletree Deakins also incurred certain necessary expenses during the Fee Period for which it is entitled to reimbursement under the terms of its retention. As set forth in greater detail in the detailed statements attached hereto as Exhibits A and B and the expense summary attached hereto as Exhibit C, Ogletree Deakins’ total expenses incurred during the Fee Period are
$81.19.
VALUATION OF SERVICES
9. The hourly rates reflected on Exhibit A are Ogletree Deakins’ customary hourly rates for work of this character. The reasonable value of the services rendered by Ogletree Deakins for the Fee Period as to the Debtors in these chapter 11 cases is $136,930.85.
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10. In accordance with section 330 of the Bankruptcy Code, the fees requested are reasonable in light of factors including, among other things, (a) the complexity of these chapter 11 cases, (b) the time expended, (c) the nature and extent of the services rendered, (d) the value of such services, and (e) the costs of comparable services other than in a case under this title.
11. Although Ogletree Deakins has made every effort to include all fees and expenses
incurred during the Fee Period in this Application, some fees and expenses might have been
omitted from this Application due to delays caused by accounting and processing during the Fee
Period. Ogletree Deakins reserves the right to submit further applications to the Court for
allowance of such fees and expenses not included herein. Subsequent fee applications will be filed
in accordance with the requirements of the Bankruptcy Code, the Bankruptcy Rules, the Local
Rules, and the Compensation Procedures Order.
CERTIFICATION OF COMPLIANCE
12. The undersigned has reviewed the requirements of Local Rule 2016-2 and certifies
that, to the best of his knowledge, information and belief, this Application complies with that rule.
[Remainder of Page Intentionally Left Blank]
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WHEREFORE, Ogletree Deakins requests payment in the aggregate amount of
$109,544.68, which is equal to (a) 80% of the $136,930.85 of total compensation earned by
Ogletree Deakins during the Fee Period for its services to the Debtors and (b) 100% of the $81.19 of necessary expenses incurred by Ogletree Deakins during the Fee Period in connection with its services to the Debtors, for a total interim award of $109,625.87.
Dated: August 18, 2020 Ogletree, Deakins, Nash, Smoak & Austin, Texas Stewart, P.C.
/s/ Bruce A. Griggs Bruce A. Griggs Shareholder 301 Congress Avenue, Suite 1150 Austin, Texas 78701 Phone: (512) 344-4700 Email: [email protected]
SPECIAL LITIGATION COUNSEL TO THE DEBTORS AND DEBTORS IN POSSESSION
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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE
In re Chapter 11
Boy Scouts of America, et al., Case No. 20-10343 (LSS)
Debtors.1 Jointly Administered
Objection Deadline: September 4, 2020, at 4:00 p.m. (ET)
NOTICE OF FIFTH MONTHLY APPLICATION OF OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C. FOR ALLOWANCE OF COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR THE PERIOD FROM JULY 1, 2020 TO AND INCLUDING JULY 31, 2020
PLEASE TAKE NOTICE that today, Ogletree, Deakins, Nash, Smoak & Stewart, P.C., as special litigation counsel to the Debtors in the above-captioned cases, filed the attached Fifth Monthly Application of Ogletree, Deakins, Nash, Smoak & Stewart, P.C. for Allowance Of Compensation and Reimbursement of Expenses for the Period from July 1, 2020 to and Including July 31, 2020 (the “Application”).
PLEASE TAKE FURTHER NOTICE that objections, if any, to the Application, must: (a) be filed with the Clerk of the Bankruptcy Court, 824 North Market Street, 3rd Floor, Wilmington, Delaware 19801, by September 4, 2020, at 4:00 p.m. (Eastern Time) (the “Objection Deadline”); and (b) be served so as to be received on or before the Objection Deadline by:
i. the Applicant: Ogletree, Deakins, Nash, Smoak & Stewart, P.C., 301 Congress Avenue, Suite 1150, Austin, Texas 78701, Attn: Bruce A. Griggs;
ii. the Debtors: Boy Scouts of America, 1325 West Walnut Hill Lane, Irving, Texas 75038, Attn: Steven P. McGowan;
iii. counsel to the Debtors: Sidley Austin LLP, 787 Seventh Avenue, New York, New York 10019, Attn: Jessica C.K. Boelter and One South Dearbon, Chicago, Illinois 60603 Attn: Matthew E. Linder;
1 The Debtors in these cases, along with the last four digits of each Debtor’s federal EIN, are as follows: Boy Scouts of America (6300) and Delaware BSA, LLC (4311). The Debtors’ mailing address is 1325 West Walnut Hill Lane, Irving, Texas 75038.
Case 20-10343-LSS Doc 1137-1 Filed 08/21/20 Page 2 of 3
iv. co-counsel to the Debtors: Morris, Nichols, Arsht & Tunnell LLP, 1201 N. Market Street, 16th Floor, Wilmington, DE 19801, Attn: Derek C. Abbott;
v. the Office of the United States Trustee: J. Caleb Boggs Federal Building, Room 2207, 844 N. King Street, Wilmington, DE 19801, Attn: David Buchbinder and Hannah M. McCollum;
vi. counsel to the Creditors’ Committee, Kramer Levin Naftalis & Frankel LLP, 1177 Avenue of the Americas, New York, New York 10036, Attn: Rachael Ringer and Megan M. Wasson;
vii. counsel to the Tort Claimants’ Committee, Pachulski Stang Ziehl & Jones LLP, 10100 Santa Monica Boulevard, 13th Floor, Los Angeles, California 90067, Attn: James I. Stang;
viii. counsel to the Future Claimants’ Representative, Young Conaway Stargatt & Taylor, LLP, Rodney Square, 1000 North King Street, Wilmington, Delaware 19801, Attn: Robert S. Brady and Edwin J. Harron;
ix. counsel to the Ad Hoc Committee of Local Councils, Wachtell, Lipton, Rosen & Katz, 51 West 52nd Street, New York, New York 10019, Attn: Richard G. Mason and Joseph C. Celentino;
x. counsel to JPMorgan Chase Bank, National Association, Norton Rose Fulbright US LLP, 2200 Ross Avenue, Dallas, Texas 75201-7932, Attn: Louis R. Strubeck and Kristian W. Gluck; and
xi. counsel to the County Commission of Fayette County (West Virginia), Steptoe & Johnson PLLC, Chase Tower – 8th Floor, 707 Virginia Street East, Charleston, West Virginia 25301, Attn: John Stump.
A HEARING ON THE APPLICATION, IF NECESSARY, WILL BE HELD AT THE CONVENIENCE OF THE COURT AND NOTICE OF ANY SUCH HEARING WILL BE GIVEN ONLY TO THE OBJECTING PARTY OR PARTIES.
IF YOU FAIL TO RESPOND IN ACCORDANCE WITH THIS NOTICE, THE COURT MAY GRANT THE RELIEF REQUESTED BY THE APPLICATION WITHOUT FURTHER NOTICE OR HEARING.
[Remainder of Page Intentionally Left Blank]
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Dated: August 21, 2020 MORRIS, NICHOLS, ARSHT & TUNNELL LLP Wilmington, Delaware /s/ Eric W. Moats Derek C. Abbott (No. 3376) Andrew R. Remming (No. 5120) Eric W. Moats (No. 6441) Paige N. Topper (No. 6470) 1201 North Market Street, 16th Floor P.O. Box 1347 Wilmington, Delaware 19899-1347 Telephone: (302) 658-9200 Facsimile: (302) 425-4664 Email: [email protected] [email protected] [email protected] [email protected]
– and –
SIDLEY AUSTIN LLP Jessica C. K. Boelter (admitted pro hac vice) 787 Seventh Avenue New York, New York 10019 Telephone: (212) 839-5300 Email: [email protected]
– and –
SIDLEY AUSTIN LLP Thomas A. Labuda (admitted pro hac vice) Michael C. Andolina (admitted pro hac vice) Matthew E. Linder (admitted pro hac vice) One South Dearborn Street Chicago, Illinois 60603 Telephone: (312) 853-7000 Email: [email protected] [email protected] [email protected]
ATTORNEYS FOR DEBTORS AND DEBTORS IN POSSESSION
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Exhibit A
Phase 1 Fees and Expense Itemization
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FILE COPY ONLY – BILL OGLETREE, DEAKINS, NASH, SUBMITTED ELECTRONICALLY SMOAK & STEWART, P.C. DO NOT SUBMIT TO CLIENT Attorneys at Law UNLESS EXPRESSLY Administrative Office REQUESTED BY CLIENT 50 International Drive Patewood IV, Suite 200 Greenville, SC 29615 August 17, 2020 Telephone: (864) 241-1900 Facsimile: (864) 241-1908 www.ogletreedeakins.com
Robyn Jungers The Boy Scouts of America Legal Department 1325 West Walnut Hill Lane P.O. Box 152079 Irving, TX 75015-2049
PERSONAL AND CONFIDENTIAL Bill # 90257759 Client.Matter # 047657.000013
Re: BSA General Defense - Bankruptcy (Billiable) Phase 1
For professional services rendered through July 31, 2020, in connection with the above-referenced matter as outlined on the attached detailed billing sheets:
Fees ...... $124,292.50 Expenses...... $81.19
Total Due This Bill...... $124,373.69
Atlanta ▪ Austin ▪ Berlin (Germany) ▪ Birmingham ▪ Boston ▪ Charleston ▪ Charlotte ▪ Chicago ▪ Cleveland ▪ Columbia ▪ Dallas ▪ Denver ▪ Detroit Metro ▪ Greenville ▪ Houston Indianapolis ▪ Jackson ▪ Kansas City ▪ Las Vegas ▪ London (England) ▪ Los Angeles ▪ Memphis ▪ Mexico City (Mexico) ▪ Miami ▪ Milwaukee ▪ Minneapolis ▪ Montréal (Canada) ▪ Morristown Nashville ▪ New Orleans ▪ New York City ▪ Oklahoma City ▪ Orange County ▪ Paris (France) ▪ Philadelphia ▪ Phoenix ▪ Pittsburgh ▪ Portland, ME ▪ Portland, OR ▪ Raleigh Richmond ▪ St. Louis ▪ St. Thomas ▪ Sacramento ▪ San Antonio ▪ San Diego ▪ San Francisco ▪ Seattle ▪ Stamford ▪ Tampa ▪ Toronto (Canada) ▪ Torrance ▪ Tucson ▪ Washington Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 3 of 88
Page 2 08/17/20 Bill No. 90257759 047657.000013-BAG
Robyn Jungers The Boy Scouts of America Legal Department 1325 West Walnut Hill Lane P.O. Box 152079 Irving, TX 75015-2049
Re: BSA General Defense - Bankruptcy (Billiable) Phase 1
For professional services rendered through July 31, 2020
Date Initials Stage Description Hours Amount 07/01/20 BAG PHASE1 Review multiple email exchanges 0.20 128.00 regarding remand of New York cases and attention to same. 07/01/20 BAG PHASE1 Telephone conference with Mike 0.30 192.00 Andolina regarding June 30 call with local council groups. 07/01/20 BAG PHASE1 Work on preparation analysis of 2.50 1,600.00 reports of claims by state and local council. 07/01/20 BAG PHASE1 Review multiple complaints filed in 1.50 960.00 New York and direct investigation and analysis of same. 07/01/20 BAG PHASE1 Multiple email exchanges and internal 1.00 640.00 team conferences regarding new open claims report, new claims asserted and tasks to be completed. 07/01/20 SEM PHASE1 Email from New Hampshire defense 0.10 44.50 counsel with court minute order in Cote case indicating the court reviewed and accepted the status report and review the same. 07/01/20 SEM PHASE1 Extensive email discussion with 0.40 178.00 Sidley regarding identification of remanded abuse matters on the Consent Order Schedule update. 07/01/20 SEM PHASE1 Internal review of BSA abuse lawsuits 0.30 133.50 that have been remanded and information necessary to include in the amended Consent Order Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 4 of 88
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Date Initials Stage Description Hours Amount Schedules. 07/01/20 SEM PHASE1 Begin review of newly filed New York 2.00 890.00 lawsuits and summarize the same for the affected local councils. 07/01/20 SEM PHASE1 Email from BSA advising of service in 0.30 133.50 the New Jersey Edwin Johnson case, review service papers and forward same to New Jersey defense counsel with direction on responding to the same. 07/01/20 SEM PHASE1 Email exchange with Chief Seattle 0.40 178.00 Council, BSA and Washington State defense counsel regarding service on the Council in recently filed lawsuits there and response to the same. 07/01/20 SEM PHASE1 Emails from New Mexico defense 0.20 89.00 counsel with Plaintiff's Motion to Compel discovery on Defendant Richard Lucero and Request for Expidited Hearing on the same in Redacted v. Lucero case remanded back to state court. 07/01/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 Winton Brown lawsuit filed in New York yesterday. 07/01/20 SEM PHASE1 Review email from Seneca 0.20 89.00 Waterways Council to BSA and attached documents related to the Winton Brown Complaint and respond accordingly. 07/01/20 SEM PHASE1 Email from Suffolk County Council in 0.10 44.50 New York with additional information related to the Winton Brown case. 07/01/20 SEM PHASE1 Review service of process documents 0.30 133.50 received from Chief Seattle Council related to the Rutz brothers and Armstrong cases. 07/01/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding I.B. (OH) claim. 07/01/20 KAD PHASE1 Revise Schedule 1 chart of pending 0.30 57.00 abuse actions to reflect state court Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 5 of 88
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Date Initials Stage Description Hours Amount information for remanded cases. 07/01/20 KAD PHASE1 Email exchange with William Curtain 0.10 19.00 and Thomas Oates regarding remanded cases and updating Schedule 1 chart of pending abuse actions to reflect same. 07/01/20 KAD PHASE1 Review email from Vanessa Savoy 0.10 19.00 regarding changes in Riskonnect and month-end reporting, forward same to Katie Murray. 07/01/20 KAD PHASE1 Review Plaintiff's First Motion to 0.20 38.00 Compel District and Motion Seeking Expedited Hearing and email from Kathleen Russell regarding same. 07/01/20 KAD PHASE1 Email exchange with Derek Bayer 0.10 19.00 regarding J.T. (NJ) pre-litigation claim. 07/01/20 KAD PHASE1 Continue identifying claims and 3.40 646.00 lawsuits that allege abuse by perpetrators not found in BSA's internal files and prepare a report of same for Heidi Steppe; link available contact records for perpetrators to claim records in Riskonnect. 07/02/20 BAG PHASE1 Conference call with Kelci Davis, 0.50 320.00 Sean Manning and Anna Kutz regarding June 30 call with local council groups. 07/02/20 BAG PHASE1 Review email from Jeremy Burton at 0.20 128.00 CNA Insurance regarding lawsuits filed and attention to same. 07/02/20 SEM PHASE1 Conference call with client to review 0.40 178.00 presentation to local council ad hoc committee and discuss next steps from the same. 07/02/20 SEM PHASE1 Email from co-defendant and 0.20 89.00 chartered organization Mount Laurel Fire Department in New Jersey regarding request to speak about BSA defense in the Burdette lawsuit and review who best to refer them to Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 6 of 88
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Date Initials Stage Description Hours Amount for response. 07/02/20 SEM PHASE1 Review email from CAN insurance 0.10 44.50 denying coverage for "various" reported abuse claims. 07/02/20 SEM PHASE1 Review Wall Street Journal article 0.30 133.50 regarding local councils allegedly selling off assets and send same to BSA and Ogletree BSA team. 07/02/20 SEM PHASE1 Review Weekly New Claims Report. 0.10 44.50 07/02/20 SEM PHASE1 Multiple email exchanges with BSA 0.40 178.00 regarding requests for information received related to various recently received lawsuits and responses to the same. 07/02/20 SEM PHASE1 Review new lawsuit filed in New York 0.80 356.00 for PC-6 DOE and summarize same for BSA and Seneca Waterways Council. 07/02/20 SEM PHASE1 Draft emails to local councils with 1.20 534.00 notice of new lawsuits and request for information related to the investigation of the same. 07/02/20 SEM PHASE1 Emails to New York defense counsel 0.80 356.00 to assign new lawsuits filed there. 07/02/20 SEM PHASE1 Research to determine current Scout 0.20 89.00 Executive of Connecticut Yankee Council and email same about new Michael Downey case. 07/02/20 SEM PHASE1 Email from Greater New York 0.20 89.00 Councils regarding information they have related to recently filed lawsuits and review the same. 07/02/20 SEM PHASE1 Email exchange with Everest 0.20 89.00 Insurance carrier regarding request for status and advice of no activity in BSA cases due to stay. 07/02/20 KAD PHASE1 Prepare weekly new claims report. 2.50 475.00 07/02/20 KAD PHASE1 Email Sidley Austin, Alvarez Marsal, 0.10 19.00 BSA and Monica Blacker regarding Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 7 of 88
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Date Initials Stage Description Hours Amount weekly new abuse claims report. 07/02/20 KAD PHASE1 Conference call with Bruce Griggs, 0.30 57.00 Sean Manning and Anna Kutz regarding call with Local Council attorneys. 07/02/20 KAD PHASE1 Review CNA coverage letter. 0.10 19.00 07/02/20 KAD PHASE1 Review Wall Street Journal news 0.10 19.00 article regarding allegations of the Local Councils moving assets around. 07/02/20 KAD PHASE1 Continue identifying claims and 2.90 551.00 lawsuits that allege abuse by perpetrators not found in BSA's internal files and prepare a report of same for Heidi Steppe; link available contact records for perpetrators to claim records in Riskonnect. 07/02/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding John Doe (DC) lawsuit and M.F. (AR) claim. 07/02/20 KAD PHASE1 Email exchange with Lynn 0.10 19.00 Richardson regarding conference call with OMNI and claims process/tracking. 07/02/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding T.G. (Nassau County) and request for information to the Council regarding same. 07/03/20 SEM PHASE1 Email exchange with Seneca 0.20 89.00 Waterways Council in New York regarding information or lack thereof related to PC-6 DOE case and possibility of obtaining Plaintiff's real name. 07/03/20 SEM PHASE1 Email exchange with Allegheny 0.20 89.00 Highlands Council regarding the lack of information related to the Robert Amitrano case in New York. 07/06/20 BAG PHASE1 Review and respond to email from 0.20 128.00 Anna Kutz regarding new assault claim reported from claimant in Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 8 of 88
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Date Initials Stage Description Hours Amount Wisconsin and attention to same. 07/06/20 BAG PHASE1 Attend conference call with Sean 0.30 192.00 Manning and Sidley team regarding Kentucky Explorer cases. 07/06/20 BAG PHASE1 Review letter from Arete Friedman at 0.20 128.00 Complex Casualty Claims regarding Paul Turley matter and attention to same. 07/06/20 BAG PHASE1 Review letter from Arete Friedman at 0.20 128.00 Complex Casualty Claims regarding Marcus Nelson matter and attention to same. 07/06/20 BAG PHASE1 Review letter from Arete Friedman at 0.20 128.00 Complex Casualty Claims regarding William Young matter and attention to same. 07/06/20 BAG PHASE1 Review information and initial 0.30 192.00 investigation materials regarding Redacted claim in Wisconsin. 07/06/20 BAG PHASE1 Review email exchange and 0.20 128.00 investigation information regarding Doe 6 v. Seneca Waterways Council. 07/06/20 BAG PHASE1 Review new claim asserted against 0.20 128.00 Suffolk County Council and internal communication with Sean Manning regarding same. 07/06/20 BAG PHASE1 Multiple email exchanges with Mike 0.30 192.00 Andolina at Sidley Austin regarding requested deposition in the Kentucky Explorer cases. 07/06/20 BAG PHASE1 Follow up email exchanges with Mike 0.20 128.00 Andolina regarding discovery issues and depositions in the Kentucky Explorer cases. 07/06/20 BAG PHASE1 Internal communications with Sean 1.50 960.00 Manning and Kelci Davis regarding new claims asserted and begin work on investigation and assessment of same. 07/06/20 BAG PHASE1 Review letter from Allie Myer at 0.20 128.00 Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 9 of 88
Page 8 08/17/20 Bill No. 90257759 047657.000013-BAG
Date Initials Stage Description Hours Amount Everest Insurance regarding dates of abuse in Unknown (FL) Omin matter and respond with confirmed dates of abuse. 07/06/20 SEM PHASE1 Review information advising no BSA 0.10 44.50 internal file for perpetrator in the new Downey lawsuit in New York. 07/06/20 SEM PHASE1 Review information advising no BSA 0.10 44.50 internal file for perpetrator in the new Klink lawsuit in New York. 07/06/20 SEM PHASE1 Review information related to new 0.20 89.00 abuse claim in Wisconsin for Redacted Redacted. 07/06/20 SEM PHASE1 Telephone call from Suffolk County 0.20 89.00 Council to advise of new summons and complaint received in a new LFL case and discussion of next steps for the same. 07/06/20 SEM PHASE1 Conference call with Sidley to discuss 0.30 133.50 strategy in Kentucky LFL cases. 07/06/20 SEM PHASE1 Email from AIG Insurance with 0.10 44.50 reservation of rights letter for the Nelson case in California. 07/06/20 SEM PHASE1 Email from AIG Insurance with 0.10 44.50 reservation of rights letter for the Young case in New York. 07/06/20 SEM PHASE1 Email exchange with Suffolk County 0.20 89.00 Council in New York regarding information related to Dennis Pfleger in the Michael J. Porchenick-Allen case and review the same. 07/06/20 SEM PHASE1 Email from AIG Insurance with 0.10 44.50 reservation of rights letter for the Turley case in California. 07/06/20 SEM PHASE1 Email to Glacier's Edge Council in 0.50 222.50 Wisconsin to introduce Ogletree and regarding the new Redacted claim and investigation into the same. 07/06/20 SEM PHASE1 Email exchange between Everest 0.20 89.00 Insurance and BSA regarding ONMI Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 10 of 88
Page 9 08/17/20 Bill No. 90257759 047657.000013-BAG
Date Initials Stage Description Hours Amount claim date confirmation for unknown Florida claim. 07/06/20 SEM PHASE1 Email from Sidley with Kentucky LFL 0.20 89.00 Plaintiff's counsel request for depositions and response related to who the individuals are and their relationship to BSA. 07/06/20 SEM PHASE1 Review extensive email exchange 0.40 178.00 between Sidley and Kentucky LFL Plaintiffs' counsel regarding BSA depositions and discovery matters. 07/06/20 SEM PHASE1 Email exchange with Seneca 0.30 133.50 Waterways Council in New York regarding documents and information related to investigation of PC-6 DOE case and review same. 07/06/20 SEM PHASE1 Email exchange with Glacier's Edge 0.10 44.50 Council in Wisconsin related to Redacted claim. 07/06/20 SEM PHASE1 Email exchange with Suffolk County 0.20 89.00 Council in New York and BSA regarding new Ingrid Kelly case and response to the same. 07/06/20 SEM PHASE1 Email exchange with Sidley regarding 0.20 89.00 obtaining input from local counsel relevant to Kentucky LFL Plaintiffs' counsel request for depositions. 07/06/20 SEM PHASE1 Review request by Kentucky LFL 0.20 89.00 Plaintiffs' counsel regarding BSA, LFL and Lincoln Heritage Council depositions with Bruce Griggs. 07/06/20 SEM PHASE1 Review information regarding lack of 0.10 44.50 BSA internal file for Greg Francis relative to the Wisconsin claim for Redacted . 07/06/20 SEM PHASE1 Email to Glacier's Edge Council in 0.10 44.50 Wisconsin to advise that BSA has no BSA internal file for Greg Francis, related to the Redacted claim. 07/06/20 SEM PHASE1 Further email exchange between 0.20 89.00 Everest Insurance and BSA regarding Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 11 of 88
Page 10 08/17/20 Bill No. 90257759 047657.000013-BAG
Date Initials Stage Description Hours Amount no coverage for unknown OMNI claim arising out of Florida. 07/06/20 SEM PHASE1 Email exchange with Sidley regarding 0.20 89.00 proposed settlement agreement (to remove from stay) for Kentucky LFL cases. 07/06/20 SEM PHASE1 Review Ingrid Kelly Lawsuit and 0.50 222.50 summarize information for New York claims processing. 07/06/20 SEM PHASE1 Telephone call from Glaciers Edge 0.20 89.00 Council in Wisconsin to discuss additional information related to Greg Francis in the Redacted matter. 07/06/20 SEM PHASE1 Multi-email discussion with Sidley and 0.40 178.00 BSA regarding proposed settlement offer, including proposed depositions and logistics of the same. 07/06/20 SEM PHASE1 Review news story from 2008 0.30 133.50 regarding Greg Francis as it related to Redacted claim in Wisconsin and send same to BSA with information gleaned therefrom. 07/06/20 SEM PHASE1 Email to New York defense counsel 0.20 89.00 to assign new Kelly Ingrid lawsuit and direct response to the same. 07/06/20 SEM PHASE1 Review spreadsheet of alleged 0.20 89.00 perpetrators not found in the BSA internal file and email BSA seeking direction to continue investigations either by perpetrator or state-by-state. 07/06/20 SEM PHASE1 Email exchange with New Jersey 0.30 133.50 defense counsel and Sidley regarding update on Pingry settlement stipulation. 07/06/20 SEM PHASE1 Email discussion between Sidley, 0.30 133.50 BSA insurance counsel and Ogletree regarding pending resolution of Kentucky LFL and BSA depositions and setting a call to discuss further. 07/06/20 SEM PHASE1 Email exchange with Sidley regarding 0.20 89.00 identification of potential Kentucky Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 12 of 88
Page 11 08/17/20 Bill No. 90257759 047657.000013-BAG
Date Initials Stage Description Hours Amount LFL deponent, Donald Moore. 07/06/20 KAD PHASE1 Search BSA's internal files for alleged 0.20 38.00 perpetrator, Norbert Osolits. 07/06/20 KAD PHASE1 Search BSA's internal files for alleged 0.20 38.00 perpetrator, Robert Preto-Rodas. 07/06/20 KAD PHASE1 Email Heidi Steppe regarding report 0.10 19.00 of alleged perpetrators not in BSA's internal files. 07/06/20 KAD PHASE1 Finish identifying claims and lawsuits 6.40 1,216.00 that allege abuse by perpetrators not found in BSA's internal files and prepare a report of same for Heidi Steppe; link available contact records for perpetrators to claim records in Riskonnect. 07/06/20 KAD PHASE1 Conference call with BSA, Monica 0.50 95.00 Blacker and OMNI agents to discuss new claims processing and procedures for same. 07/06/20 KAD PHASE1 Search BSA's internal files for alleged 0.20 38.00 perpetrator, Greg Francis. 07/06/20 KJM PHASE1 Analyze/review Complaint in 0.10 15.00 preparation for entering new claim into Riskonnect. (NY-Winter, Eric). 07/06/20 KJM PHASE1 Create new claim in Riskonnect in 0.50 75.00 preparation for litigation per Robyn Jungers request. (NY- Winter, Eric). 07/06/20 KJM PHASE1 Analyze/review Complaint in 0.10 15.00 preparation for entering new claim into Riskonnect. (NY-Stevens, Alan). 07/06/20 KJM PHASE1 Create new claim in Riskonnect in 0.40 60.00 preparation for litigation per Robyn Jungers request. (NY-Stevens, Alan). 07/07/20 BAG PHASE1 Multiple email exchanges with Mike 1.00 640.00 Andolina and Sean Manning regarding discovery issues in the Kentucky Explore cases and internal communications regarding resolution of those issues. Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 13 of 88
Page 12 08/17/20 Bill No. 90257759 047657.000013-BAG
Date Initials Stage Description Hours Amount 07/07/20 BAG PHASE1 Multiple email exchanges with Paul 0.20 128.00 Needham at Aspen Insurance regarding status of the Redacted claim in Pennsylvania. 07/07/20 BAG PHASE1 Internal team meetings and calls to 1.00 640.00 review most recently filed claims. 07/07/20 SEM PHASE1 Email exchange with Sidley regarding 0.20 89.00 resolution of objection to the stay matters related to the Kentucky LFL cases. 07/07/20 SEM PHASE1 Emails exchange with BSA to discuss 0.30 133.50 further research and investigation on spreadsheet of alleged perpetrators not in BSA internal files over state-by- state claims. 07/07/20 SEM PHASE1 Conference call with Sidley team to 0.20 89.00 discuss postponement of BSA and LFL depositions in Kentucky and potential for more information needed should they go forward at a later time. 07/07/20 SEM PHASE1 Email exchange with Minsi Trails 0.20 89.00 Council in Pennsylvania regarding news article related to current litigation there between a former abuse victim and the Allentown Diocese and Hellertown school that included a Scouting connection. 07/07/20 SEM PHASE1 Review news article received from 0.10 44.50 Minsi Trails Council in Pennsylvania related to possible forthcoming BSA abuse claim. 07/07/20 SEM PHASE1 Review information related to BSA 0.40 178.00 internal files found or not found related to newly filed New York lawsuits. 07/07/20 SEM PHASE1 Email from Sidley confirming a 0.10 44.50 resolution with the Kentucky LFL Plaintiffs. 07/07/20 SEM PHASE1 Review and respond regarding BSA 0.20 89.00 insurance carrier request for defense counsel information in the Redacted Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 14 of 88
Page 13 08/17/20 Bill No. 90257759 047657.000013-BAG
Date Initials Stage Description Hours Amount matter in Pennsylvania. 07/07/20 SEM PHASE1 Review Greg Francis BSA internal 0.30 133.50 files related to Redacted claim in Wisconsin. 07/07/20 SEM PHASE1 Email from BSA with letter of 0.20 89.00 representation for John Harrell and review the same. 07/07/20 SEM PHASE1 Review Jody Harrell claim for 0.10 44.50 information pertinent to the John Harrell claim. 07/07/20 SEM PHASE1 Review chart containing information 0.50 222.50 related to alleged BSA abuse claim perpetrators not in BSA internal files in preparation to begin research to create the same. 07/07/20 SEM PHASE1 Email exchange with Seneca 0.20 89.00 Waterways Council and BSA regarding insurance matters related to specific years and claims from those time periods. 07/07/20 SEM PHASE1 Email exchange with Simon Kenton 0.20 89.00 Council in Ohio regarding a lack of information related to the Redacted claim. 07/07/20 SEM PHASE1 Review email from Sidley regarding 0.10 44.50 discussions with Kentucky LFL Plaintiffs and need for follow-up with Defense counsel. 07/07/20 SEM PHASE1 Email exchange with Kentucky 0.30 133.50 defense counsel with proposed joint status agreement and request for confirmation of lifting the stay in the LFL cases and forward report to Sidley for review and input. 07/07/20 SEM PHASE1 Review proposed joint status report in 0.10 44.50 Kentucky LFL cases. 07/07/20 SEM PHASE1 Review email from Sidley with 0.40 178.00 background information related to the I.G. case in Missouri and agreement to continue discovery related to the same and forward same to local Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 15 of 88
Page 14 08/17/20 Bill No. 90257759 047657.000013-BAG
Date Initials Stage Description Hours Amount defense counsel to provide information related to the same. 07/07/20 SEM PHASE1 Telephone call with Sidley seeking an 0.10 44.50 agreement from the Ozark Trails Council in Missouri to provide asset information to plaintiff's counsel in the I.G. case to get agreement to lift stay. 07/07/20 SEM PHASE1 Telephone call and email to Ozark 0.30 133.50 Trails Council seeking approval to provide asset information for agreement with Plaintiff's counsel in the I.G. case to maintain stay. 07/07/20 SEM PHASE1 Review information related to seven 0.10 44.50 new lawsuits filed in New York. 07/07/20 SEM PHASE1 Email exchange with Sidley seeking 0.20 89.00 permission to provide the Pfau Cochran group the Proof of Claim and Notice information and seek the cessation of lawsuit filings in New York. 07/07/20 SEM PHASE1 Email from BSA with service of 0.20 89.00 process information in the Edwin Johnson lawsuit in New Jersey and review the same. 07/07/20 SEM PHASE1 Email to New Jersey defense counsel 0.10 44.50 with service of process information on BSA and authorization to file Notice of Second Extension to the Consent Order in the Edwin Johnson case. 07/07/20 SEM PHASE1 Email from Sidley approving of the 0.20 89.00 proposed joint status report in the Kentucky LFL cases and forward said approval to local defense counsel. 07/07/20 KAD PHASE1 Review letter of representation for 0.10 19.00 John Harrell and email from Anna Kutz regarding same. 07/07/20 KAD PHASE1 Review email from Anna Kutz 0.10 19.00 regarding lawsuit filed by Ingrid Kelly. 07/07/20 KAD PHASE1 Search BSA's internal files for alleged 1.10 209.00 perpetrators named in various New Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 16 of 88
Page 15 08/17/20 Bill No. 90257759 047657.000013-BAG
Date Initials Stage Description Hours Amount York lawsuits. 07/07/20 KAD PHASE1 Begin compiling and manipulating 5.20 988.00 case and claim data in preparation of preparing Local Council claims reports. 07/08/20 BAG PHASE1 Review and respond to email from 0.20 128.00 defense counsel in MM Doe. Northern New Jersey Council regarding lift of stay. 07/08/20 BAG PHASE1 Initial review and analysis of five new 0.50 320.00 lawsuits in New York direct investigation regarding same. 07/08/20 BAG PHASE1 Review multiple email exchanges 0.50 320.00 with defense counsel in Kentucky Explorer cases and coordinate preparation of LFL witnesses for depositions with Sean Manning. 07/08/20 BAG PHASE1 Review status update received from 0.20 128.00 defense counsel in KY Explorer cases and internal communications with Sean Manning regarding same. 07/08/20 BAG PHASE1 Review email exchanges regarding 0.20 128.00 discovery issues in I.G. v BSA matter and attention to same. 07/08/20 BAG PHASE1 Review email status update from 0.10 64.00 defense counsel in Jane Doe v Town of Trumbull and attention to same. 07/08/20 BAG PHASE1 Review and respond to email from 0.20 128.00 Mike Andolina regarding providing claims information to insurers and attention to same. 07/08/20 SEM PHASE1 Email exchange with Sidley regarding 0.20 89.00 status of Ozark Trails agreement to produce council asset information in the I.G. case. 07/08/20 SEM PHASE1 Telephone call and email with Ozark 0.20 89.00 Trails Council team regarding status of agreement to produce council asset information in the I.G. case. 07/08/20 SEM PHASE1 Email exchange with New Jersey 0.20 89.00 Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 17 of 88
Page 16 08/17/20 Bill No. 90257759 047657.000013-BAG
Date Initials Stage Description Hours Amount defense counsel regarding potential discovery issue in the John MM Doe case. 07/08/20 SEM PHASE1 Review documents and information 0.20 89.00 received from the Glacier's Edge Council related to the Redacted Redacted matter. 07/08/20 SEM PHASE1 Review BSA internal files for Wilson 0.50 222.50 Arthur Nelson to determine if he is the same perpetrator identified in AIS claims and update claims spreadsheet. 07/08/20 SEM PHASE1 Email from Sidley advising they came 0.10 44.50 to an agreement with Plaintiff's counsel in the Missouri I.G. case regarding asset discovery for Ozark Trails Council. 07/08/20 SEM PHASE1 Telephone call from Ozark Trails 0.10 44.50 Council regarding status update on coming to a consensus with the council team on an agreement to produce council asset information. 07/08/20 SEM PHASE1 Email exchange with local defense 0.20 89.00 counsel in Kentucky regarding Plaintiff's request for LFL and council depositions. 07/08/20 SEM PHASE1 Email to Sidley regarding Kentucky 0.20 89.00 Plaintiff's request for LFL and council depositions and background on proposed deponents. 07/08/20 SEM PHASE1 Email from local Connecticut defense 0.20 89.00 counsel with Plaintiff's offers to Compromise filed against the non- BSA defendants and review same. 07/08/20 SEM PHASE1 Review new lawsuits filed in New 1.50 667.50 York and summarize claims and information to provide local councils and for investigation of the same. 07/08/20 SEM PHASE1 Email New York defense counsel to 0.30 133.50 assign new lawsuits. 07/08/20 SEM PHASE1 Review BSA internal files for William 0.20 89.00 Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 18 of 88
Page 17 08/17/20 Bill No. 90257759 047657.000013-BAG
Date Initials Stage Description Hours Amount Baker from new Daryl Janczyk case filed in New York. 07/08/20 SEM PHASE1 Email notices to local councils 0.80 356.00 regarding new lawsuits filed in New York with requests for investigation of the same. 07/08/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 Alexander Fire Department notice of tender for Fye lawsuit filed in New York. 07/08/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 service of the Bobeck lawsuit in New York. 07/08/20 SEM PHASE1 Email to New York defense counsel 0.10 44.50 to advise of service of Bobeck lawsuit on the Greater Niagara Frontier Council and direction to file notice of second consent order extension. 07/08/20 SEM PHASE1 Email exchange with attorney for 0.20 89.00 Ozark Trails Council to confirm discovery production of council assets is covered by bankruptcy court protective order. 07/08/20 SEM PHASE1 Email from Ozark Trails Council 0.10 44.50 approving of council asset information being produced in discovery. 07/08/20 SEM PHASE1 Email exchange with Sidley regarding 0.20 89.00 documents produced to BSA insurance carriers prior to November 2019 mediation, prior to producing same to the Tort Claims Committee. 07/08/20 SEM PHASE1 Email exchange with Pennsylvania 0.30 133.50 defense counsel in regard to the Notice of Second Extension of the Consent Order prepared for filing in the Edwin Johnson matter in New Jersey, review and approve the same. 07/08/20 SEM PHASE1 Email exchange with Pennsylvania 0.30 133.50 defense counsel in regard to the Notice of Second Extension of the Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 19 of 88
Page 18 08/17/20 Bill No. 90257759 047657.000013-BAG
Date Initials Stage Description Hours Amount Consent Order prepared for filing in the removed Dieterly matter, review and approve the same. 07/08/20 SEM PHASE1 Email to the Hudson Valley Council 0.30 133.50 regarding the Rob Cummings lawsuit with summary of the same and request for information. 07/08/20 SEM PHASE1 Email exchange with Sidley and New 0.30 133.50 Jersey defense counsel regarding bankruptcy court entering order approving the stipulation to settle and dismiss the Pingry/M.F. lawsuit and review said order. 07/08/20 SEM PHASE1 Email exchange with Sidley regarding 0.20 89.00 titles of individuals noticed for deposition in the Kentucky LFL cases. 07/08/20 SEM PHASE1 Email exchange with Greater Niagara 0.20 89.00 Frontier Council in New York regarding search for information related to the Janczyk and Bobeck cases. 07/08/20 SEM PHASE1 Telephone call from Washington 0.10 44.50 State defense counsel regarding direction for filing Notices of Second Extension of Consent Order and not removals in all four new lawsuits filed there. 07/08/20 SEM PHASE1 Email from Washington State defense 0.10 44.50 counsel with Notices of Appearance filed in all four new lawsuits filed there. 07/08/20 SEM PHASE1 Review information provided to Sidley 0.10 44.50 regarding information regularly provided to Chubb Insurance regarding claims falling within their coverage years. 07/08/20 KAD PHASE1 Review email from Anna Kutz 0.10 19.00 regarding service of process of Edwin Johnson lawsuit. 07/08/20 KAD PHASE1 Email exchange with Desiree Vale 0.10 19.00 Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 20 of 88
Page 19 08/17/20 Bill No. 90257759 047657.000013-BAG
Date Initials Stage Description Hours Amount regarding BSA's First Omnibus Fee Order. 07/08/20 KAD PHASE1 Search BSA's internal files for alleged 0.40 76.00 perpetrators named in Janczyk, Cummings and Singletary lawsuits. 07/08/20 KAD PHASE1 Review email from Joseph Odea 0.10 19.00 regarding draft Notice of Entry of Second Stipulation and Agreed Order. 07/08/20 KAD PHASE1 Review email from Anna Kutz 0.10 19.00 regarding service of process in Bobeck lawsuit on Greater Niagara Frontier Council. 07/08/20 KAD PHASE1 Review Utica's tender letter to 0.20 38.00 Iroquois Trail Council regarding the defense and indemnity of Alexander Fire Department in the Joshua Fye lawsuit. 07/08/20 KAD PHASE1 Continue compiling and manipulating 6.00 1,140.00 case and claim data in preparation of preparing Local Council claims reports. 07/08/20 KAD PHASE1 Email exchange with Nicole 0.10 19.00 Liberatore regarding filing of Notice of Entry of Second Stipulation and Agreed Order. 07/09/20 BAG PHASE1 Review and assess new Complaint in 0.50 320.00 Kelly v. Suffolk County Council and attention to same. 07/09/20 BAG PHASE1 Review Complaint in Thomas v. 0.20 128.00 Westchester Council and internal communications with Sean Manning regarding same. 07/09/20 BAG PHASE1 Review Order approving stipulation of 0.20 128.00 dismissal in Pingry School case and attention to same. 07/09/20 BAG PHASE1 Review lift stay Orders entered by the 0.20 128.00 bankruptcy court and attention to same. 07/09/20 BAG PHASE1 Review/analyze Court Order’s on 0.50 320.00 Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 21 of 88
Page 20 08/17/20 Bill No. 90257759 047657.000013-BAG
Date Initials Stage Description Hours Amount multiple motions to lift stays and attention to same. 07/09/20 BAG PHASE1 Review/analyze Orders relating to 0.50 320.00 insurance carriers ability to settle certain abuse and non-abuse claims and internal team communications regarding same. 07/09/20 BAG PHASE1 Review email from defense counsel 0.20 128.00 in Doe v. Cascade Charter Township (MI) and forward with email correspondence to Mike Andolina at Sidley Austin. 07/09/20 BAG PHASE1 Review email from AIG claims 0.20 128.00 examiner requesting Complaints and information and forward with email correspondence to Adrian Azur. 07/09/20 BAG PHASE1 Review Complaint in PC Doe 11 v. 0.20 128.00 Longhouse Council and attention to same. 07/09/20 BAG PHASE1 Review Complaints in Cirolo and 0.40 256.00 Cruz matters filed against the Greater New York Council and attention to same. 07/09/20 SEM PHASE1 Email exchange with Sidley regarding 0.20 89.00 BSA never being named in the Kentucky LFL lawsuits. 07/09/20 SEM PHASE1 Email from BSA regarding new 0.10 44.50 lawsuit filed and served on Westchester-Putnam Council in New York for Thomas Kreiser. 07/09/20 SEM PHASE1 Review new lawsuit filed by Thomas 0.40 178.00 Kreiser in New York and summarize the same for information to provide Westchester-Putnam Council and defense counsel. 07/09/20 SEM PHASE1 Email to New York defense counsel 0.20 89.00 with assignment of new Thomas Kreiser lawsuit, background on the same, and authority to file Notice of Second Extension of the Consent Order. Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 22 of 88
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Date Initials Stage Description Hours Amount 07/09/20 SEM PHASE1 Email to Westchester-Putnam 0.20 89.00 Council acknowledging receipt of Thomas Kreiser lawsuit and action on same. 07/09/20 SEM PHASE1 Review and gather information 1.80 801.00 regarding alleged perpetrators not in BSA internal files from the spreadsheet of claims and prepare summaries to send Councils seeking information and documents related to the same. 07/09/20 SEM PHASE1 Email from Michigan defense counsel 0.30 133.50 with stipulation for protective order filed by Plaintiff and Cascade Township in the Jane Doe matter regarding discovery outside the stay, review same and forward to Sidley for input on the same. 07/09/20 SEM PHASE1 Email from AIG insurance seeking 0.30 133.50 complaints and information related to numerous lawsuits, and discuss same with BSA insurance counsel. 07/09/20 SEM PHASE1 Review three new lawsuits filed in 0.80 356.00 New York and summarize claims to send to councils and defense counsel. 07/09/20 SEM PHASE1 Email local New York defense 0.40 178.00 counsel to assign additionally received new lawsuits. 07/09/20 SEM PHASE1 Email to Greater New York Councils 0.30 133.50 with newly filed lawsuits and requests for documents and information related to same. 07/09/20 SEM PHASE1 Review BSA internal files for Charles 0.60 267.00 Seamans and John Rosenquist from newly filed New York lawsuits. 07/09/20 SEM PHASE1 Email to Longhouse Council in New 0.20 89.00 York with new lawsuit filed for PC-11 DOE and request for information related to Charles Seamans. 07/09/20 SEM PHASE1 Email from Westchester-Putnam 0.10 44.50 Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 23 of 88
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Date Initials Stage Description Hours Amount Council regarding a lack of information related to the Thomas Kreiser case. 07/09/20 SEM PHASE1 Email from claimant's counsel 0.20 89.00 seeking contact information for ad hoc committee of local councils attorneys and forward request for same to Sidley. 07/09/20 SEM PHASE1 Draft email to Transatlantic Council 0.60 267.00 introducing Ogletree and requesting information and documents related to multi-plaintiff group claims with perpetrators not in BSA internal files. 07/09/20 SEM PHASE1 Draft email to Far East Council 0.30 133.50 introducing Ogletree and requesting information and documents related to multi-plaintiff group claims with perpetrators not in BSA internal files. 07/09/20 KAD PHASE1 Email Sidley Austin and Haynes and 0.10 19.00 Boone regarding Chubb claims spreadsheet. 07/09/20 KAD PHASE1 Prepare Chubb claims spreadsheet. 1.60 304.00 07/09/20 KAD PHASE1 Review email from Anna Kutz 0.10 19.00 regarding new lawsuit filed by Thomas Kreiser. 07/09/20 KAD PHASE1 Communicate with Jennifer Nichols 0.10 19.00 regarding relationship between perpetrator and claimant, M.R. 07/09/20 KAD PHASE1 Email exchange with Nicole 0.10 19.00 Liberatore regarding filing of Notice of Entry of Second Stipulation and Agreed Order in Bobeck lawsuit. 07/09/20 KAD PHASE1 Search BSA's internal files for alleged 0.60 114.00 perpetrators named in Kreiser, Seamans and Rosenquist lawsuits. 07/09/20 KAD PHASE1 Continue compiling and manipulating 4.40 836.00 case and claim data in preparation of preparing Local Council claims reports. 07/10/20 BAG PHASE1 Review email from attorney 0.20 128.00 Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 24 of 88
Page 23 08/17/20 Bill No. 90257759 047657.000013-BAG
Date Initials Stage Description Hours Amount representing NY claimants and exchange email with Mike Andolini regarding same. 07/10/20 BAG PHASE1 Review representation letter received 0.20 128.00 from counsel for Redacted and attention to same. 07/10/20 SEM PHASE1 Email exchange with BSA regarding 0.50 222.50 California defense counsel billing for Redacted and Kutz cases and investigate same. 07/10/20 SEM PHASE1 Email exchange with Georgia 0.10 44.50 defense counsel regarding Georgia Supreme Court declaration of a judicial emergency, and no answers to be filed until September. 07/10/20 SEM PHASE1 Email form Longhouse Council with 0.30 133.50 material relevant to the PC-11 DOE case, review same and forward to BSA. 07/10/20 SEM PHASE1 Review News Story regarding BSA 0.20 89.00 bankruptcy hearing yesterday and forward same to BSA. 07/10/20 SEM PHASE1 Email exchange with claimant's 0.30 133.50 counsel regarding proof of claim filings and information related to constitutional objection for extending New York statute of limitations. 07/10/20 SEM PHASE1 Email discussion with Sidley 0.40 178.00 regarding providing contact information for Ricky Mason to claimant's counsel and forward same to claimant's counsel. 07/10/20 SEM PHASE1 Email exchange with Florida defense 0.20 89.00 counsel regarding court ordered status report from bankruptcy hearing and information regarding the same. 07/10/20 SEM PHASE1 Email from California defense 0.20 89.00 counsel with Thomas Rule 26 report and forward same to BSA per request for same. 07/10/20 SEM PHASE1 Email from BSA with notice of new 0.20 89.00 Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 25 of 88
Page 24 08/17/20 Bill No. 90257759 047657.000013-BAG
Date Initials Stage Description Hours Amount claim arising out of Old North State Council and review the same. 07/10/20 SEM PHASE1 Email to Old North State Council 0.20 89.00 regarding new Redacted claim and further action on the same. 07/10/20 SEM PHASE1 Email from California defense 0.20 89.00 counsel advising they do not have the Kutz case and forward information to BSA advising of such. 07/10/20 SEM PHASE1 Email to Claimant's counsel in the 0.50 222.50 Redacted matter in North Carolina and provide proof of claim form for the same. 07/10/20 SEM PHASE1 Email from counsel for claimant 0.10 44.50 Redacted in North Carolina regarding filing a proof of claim in the BSA bankruptcy case. 07/10/20 SEM PHASE1 Review weekly BSA abuse claims 0.10 44.50 report. 07/10/20 SEM PHASE1 Further email exchange with 0.30 133.50 claimant's counsel and Sidley regarding filing proofs of claim and working with local council and tort claim committee attorneys regarding New York statute of limitations matters. 07/10/20 SEM PHASE1 Review news article from Missouri 0.30 133.50 about Scoutmaster abusing boys and send same to BSA with request for input on whether we know if boys he abused were Scouts.. 07/10/20 KAD PHASE1 Email exchange with William Curtain 0.10 19.00 regarding Norman Wolfe lawsuit. 07/10/20 KAD PHASE1 Review email from Matt Martin 0.10 19.00 regarding status update on Hall County cases. 07/10/20 KAD PHASE1 Analyze rosters, news article and 0.30 57.00 person listing received from the Longhouse Council in connection with the lawsuit filed by PC-11 Doe,. Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 26 of 88
Page 25 08/17/20 Bill No. 90257759 047657.000013-BAG
Date Initials Stage Description Hours Amount 07/10/20 KAD PHASE1 Prepare weekly new claims report. 2.50 475.00 07/10/20 KAD PHASE1 Email Sidley Austin, Alvarez Marsal, 0.10 19.00 BSA and Monica Blacker regarding weekly new abuse claims report. 07/10/20 KAD PHASE1 Email exchange with Anna Kutz 0.10 19.00 regarding entering new R.C. (NC) claim in Riskonnect. 07/10/20 KAD PHASE1 Email exchange with Michael 0.10 19.00 Andolina regarding Chubb claims spreadsheet. 07/10/20 KAD PHASE1 Search BSA's internal files for alleged 0.20 38.00 perpetrator named in R.C. (NC) claim. 07/10/20 KAD PHASE1 Email exchange with William Curtain 0.10 19.00 regarding receipt of new lawsuits filed by Pfau Cochran. 07/10/20 KJM PHASE1 Analyze/review Complaint in 0.20 30.00 preparation for entering new claim into Riskonnect. (NY-Klink, Christopher). 07/10/20 KJM PHASE1 Create new claim in Riskonnect in 0.50 75.00 preparation for litigation per Robyn Jungers request. (NY-Klink, Christopher). 07/10/20 KJM PHASE1 Analyze/review Complaint in 0.20 30.00 preparation for entering new claim into Riskonnect. (NY-Downey, Michael). 07/10/20 KJM PHASE1 Create new claim in Riskonnect in 0.40 60.00 preparation for litigation per Robyn Jungers request. (NY-Downey, Michael). 07/13/20 BAG PHASE1 Review email from defense counsel 0.10 64.00 in A.A. v BSA (FL) regarding joint status report. 07/13/20 BAG PHASE1 Review media report regarding 0.10 64.00 arrested former Scout Master in Kansas. 07/13/20 BAG PHASE1 Review and assess report of new 1.50 960.00 Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 27 of 88
Page 26 08/17/20 Bill No. 90257759 047657.000013-BAG
Date Initials Stage Description Hours Amount abuse claims received after July 2, 2020. 07/13/20 BAG PHASE1 Review draft Notice of Entry of 0.20 128.00 Consent Order in Dieterly v BSA and attention to same. 07/13/20 BAG PHASE1 Review closure order in New Jersey 0.10 64.00 case. 07/13/20 BAG PHASE1 Review and assess multiple new 2.50 1,600.00 complaints filed in New York and internal communications with Ogletree team regarding same. 07/13/20 SEM PHASE1 Review multiple news stories online 0.60 267.00 regarding new BSA abuse matters from Ohio, Missouri and Illinois, summarized said stories and send same to BSA. 07/13/20 SEM PHASE1 Review email from Florida defense 0.10 44.50 counsel with Order from court approving of second Joint Status Report and extending stay of litigation until November 16, 2020 in the A.A. case. 07/13/20 SEM PHASE1 Continue review of spreadsheet of 1.30 578.50 AIS claims with alleged perpetrators not in BSA internal files. 07/13/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 request for follow-up on information related to new lawsuit in Hawaii. 07/13/20 SEM PHASE1 Review issue of potential bad 0.50 222.50 information related to dates of birth and dates of abuse in the John Doe 1-8 case in Hawaii and email defense counsel seeking a conference with Plaintiff's counsel to pin down the same. 07/13/20 SEM PHASE1 Review information previously sought 0.20 89.00 from Aloha Council related to John Roe 1-8 case and follow-up on the same. 07/13/20 SEM PHASE1 Emails from Florida defense counsel 0.30 133.50 regarding court closure of the N.G. Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 28 of 88
Page 27 08/17/20 Bill No. 90257759 047657.000013-BAG
Date Initials Stage Description Hours Amount case pending further status report on November 25, 2020 and review said orders. 07/13/20 SEM PHASE1 Begin preparing emails to local 1.50 667.50 councils with information related to search for information and documents for alleged AIS group perpetrators not in BSA internal files. 07/13/20 SEM PHASE1 Email from Berkley Insurance 0.20 89.00 Company regarding coverage for the Coats claim and review the same. 07/13/20 SEM PHASE1 Email exchange with Hawaii defense 0.20 89.00 counsel regarding additional information related to service of John Roe 1-8 lawsuit and information gathering for the same. 07/13/20 SEM PHASE1 Email exchange with Anthony Wayne 0.30 133.50 Area Council regarding information related to AIS-0954 claim and other potential claims against this council. 07/13/20 SEM PHASE1 Email exchange with Rip Van Winkle 0.30 133.50 Council in New York regarding the Louis Morales lawsuit and information located in council records related to the same and review said records. 07/13/20 KAD PHASE1 Analyze lawsuit filed by Timothy 0.20 38.00 Shaffer in preparation of entering same in Riskonnect. 07/13/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by Timothy Shaffer. 07/13/20 KAD PHASE1 Analyze lawsuit filed by Perry Murphy 0.20 38.00 in preparation of entering same in Riskonnect. 07/13/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by Perry Murphy. 07/13/20 KAD PHASE1 Review Chillicothe Gazette news 0.10 19.00 article regarding an open letter released on social media of a Scout leader admitting to being a child molester. Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 29 of 88
Page 28 08/17/20 Bill No. 90257759 047657.000013-BAG
Date Initials Stage Description Hours Amount 07/13/20 KAD PHASE1 Analyze lawsuit filed by Daryl 0.20 38.00 Janczyk in preparation of entering same in Riskonnect. 07/13/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by Daryl Janczyk. 07/13/20 KAD PHASE1 Review email from Jennifer Nichols 0.10 19.00 regarding request for information to the Local Council in connection with the lawsuit filed by John Roe 1. 07/13/20 KAD PHASE1 Communicate with Jennifer Nichols 0.10 19.00 via Chatter regarding John Roe 1's date of birth. 07/13/20 KAD PHASE1 Analyze lawsuit filed by Scott 0.20 38.00 Singletary in preparation of entering same in Riskonnect. 07/13/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by Scott Singletary. 07/13/20 KAD PHASE1 Analyze case file and documents to 0.30 57.00 determine discrepancy in John Roe 1's alleged years of abuse and date of birth. 07/13/20 KAD PHASE1 Communicate with Jennifer Nichols 0.10 19.00 via Chatter regarding discrepancy in the alleged years of abuse and John Roe 2's date of birth. 07/13/20 KAD PHASE1 Compile new case and claim 1.80 342.00 information to assist attorney with valuing same. 07/13/20 KJM PHASE1 Analyze/review Complaint in 0.20 30.00 preparation for entering new claim into Riskonnect. (NY-Brown, Winton). 07/13/20 KJM PHASE1 Create new claim in Riskonnect in 1.10 165.00 preparation for litigation per Robyn Jungers request. (NY-Brown, Winton). 07/14/20 BAG PHASE1 Review email from Richard Stockton 0.10 64.00 with Westchester-Putnam Council regarding the Thomas Kreiser matter. 07/14/20 BAG PHASE1 Appear for and attend conference call 1.00 640.00 Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 30 of 88
Page 29 08/17/20 Bill No. 90257759 047657.000013-BAG
Date Initials Stage Description Hours Amount with Sidley Austin team and other defense counsel regarding going forward strategy. 07/14/20 BAG PHASE1 Prepare for and attend conference 0.50 320.00 call with Sidley Austin team to address the Kentucky Explorer cases. 07/14/20 BAG PHASE1 Internal team meeting to discuss 1.00 640.00 pending claims and assign tasks. 07/14/20 SEM PHASE1 Review news stories regarding BSA 0.30 133.50 bankruptcy and potential for additional states opening their statutes of limitations. 07/14/20 SEM PHASE1 Email exchange with Kentucky LFL 0.20 89.00 defense counsel regarding Plaintiffs' attempt to obtain discovery and for input on requested depositions prior to tomorrow's discovery/status hearing. 07/14/20 SEM PHASE1 Email to Sidley regarding information 0.10 44.50 obtained from Kentucky LFL defense counsel about Plaintiffs' attempt to obtain discovery and for input on requested depositions prior to tomorrow's discovery/status hearing. 07/14/20 SEM PHASE1 Email to Anthony Wayne Area 0.20 89.00 Council and BSA with input on information received related to AIS- 0954 claim and response from BSA regarding the same. 07/14/20 SEM PHASE1 Email exchange with Sidley regarding 0.20 89.00 BSA ScoutNet and RMIS systems. 07/14/20 SEM PHASE1 Review service information for John 0.20 89.00 Roes 1-8 case in Hawaii and email Aloha Council to confirm service. 07/14/20 SEM PHASE1 Email exchange with Allegheny 0.20 89.00 Highlands Council in New York regarding ability to share information related to Amitrano case with Council attorney. 07/14/20 SEM PHASE1 Email exchange with Westchester- 0.20 89.00 Putnam Council in New York Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 31 of 88
Page 30 08/17/20 Bill No. 90257759 047657.000013-BAG
Date Initials Stage Description Hours Amount regarding lack of information related to Thomas Kreiser lawsuit and follow- up seeking further search. 07/14/20 SEM PHASE1 Email from Westchester-Putnam 0.20 89.00 Council in New York clarifying lack of information related to Thomas Kreiser case and forward request to BSA for NESA file on alleged perpetrator. 07/14/20 SEM PHASE1 Email exchange with Sidley and 0.20 89.00 Kentucky defense counsel regarding possible call today about Plaintiff's discovery efforts. 07/14/20 SEM PHASE1 Email from Atlanta Area Council 0.10 44.50 regarding search for documents and material related to AIS claims. 07/14/20 SEM PHASE1 Review email exchange between 0.30 133.50 BSA and Aloha Council regarding documents related to John Roe 1-8 case and review of the same. 07/14/20 SEM PHASE1 Email from Baltimore Area Council 0.10 44.50 regarding search for records related to the AIS claims. 07/14/20 SEM PHASE1 Email from Sidley regarding counsel 0.20 89.00 to include on Kentucky discovery call and confirmation from Kentucky defense counsel about the same. 07/14/20 SEM PHASE1 Continue drafting emails to send to 1.30 578.50 local BSA councils regarding investigation of AIS claims without alleged perpetrator BSA internal files. 07/14/20 SEM PHASE1 Email from Bay Area Council 0.10 44.50 regarding beginning search for AIS claim information. 07/14/20 SEM PHASE1 Arrange for Kentucky defense 0.20 89.00 counsel to join conference call with Sidley to discuss Plaintiff's discovery issues. 07/14/20 SEM PHASE1 Continue review of spreadsheet of 1.00 445.00 AIS claims with alleged perpetrators not in BSA internal files and gather those for additional investigation with Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 32 of 88
Page 31 08/17/20 Bill No. 90257759 047657.000013-BAG
Date Initials Stage Description Hours Amount the local councils. 07/14/20 SEM PHASE1 Conference call with Sidley and 0.40 178.00 Kentucky defense team regarding LFL Plaintiffs' discovery demands. 07/14/20 SEM PHASE1 Email exchange with Sidley in follow- 0.20 89.00 up to conference call with Kentucky defense counsel regarding attendance at discovery conference tomorrow. 07/14/20 SEM PHASE1 Further review of Kentucky discovery 0.20 89.00 issue and email to Sidley regarding need to avoid direct Ogletree intervention. 07/14/20 SEM PHASE1 Email to LFL regarding potential 0.30 133.50 Kentucky LFL deposition and background on the same. 07/14/20 KAD PHASE1 Review court's order administratively 0.10 19.00 closing the N.G. (FL) case. 07/14/20 KAD PHASE1 Review rosters received from Council 0.20 38.00 in connection with the lawsuit filed by Louis Morales. 07/14/20 KAD PHASE1 Compile BSA claim numbers for 0.30 57.00 various Montana claims. 07/14/20 KAD PHASE1 Email exchange with Tina Sunderland 0.10 19.00 regarding BSA claim numbers for various Montana claims assigned to Boone Karlberg. 07/14/20 KAD PHASE1 Finish compiling and manipulating 6.80 1,292.00 case and claim data in preparation of preparing Local Council claims reports. 07/15/20 BAG PHASE1 Review email from defense counsel 0.20 128.00 in Kentucky Explorer cases regarding planned review of 100,000 pages of documents and attention to same. 07/15/20 BAG PHASE1 Email to Anna Kutz regarding 0.10 64.00 document review in Kentucky Explorer cases. 07/15/20 BAG PHASE1 Review status report received from 0.10 64.00 Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 33 of 88
Page 32 08/17/20 Bill No. 90257759 047657.000013-BAG
Date Initials Stage Description Hours Amount defense counsel in Kentucky Explorer cases. 07/15/20 SEM PHASE1 Email exchange with New York 0.20 89.00 defense counsel regarding extension of Child Victims Act statute of limitations for filing abuse lawsuits. 07/15/20 SEM PHASE1 Review and summarize news story 0.30 133.50 from New York regarding the Child Victims Act statute of limitations being extended and forward same to BSA with background information from conversations with claimant's counsel. 07/15/20 SEM PHASE1 Further email exchange with New 0.20 89.00 York defense counsel regarding issue of plaintiff's trying to get to the local councils assets. 07/15/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 six newly filed lawsuits in New York. 07/15/20 SEM PHASE1 Email exchange with Kentucky 0.20 89.00 defense counsel regarding need for authorization to review documents produced in discovery by other parties in preparation for upcoming depositions. 07/15/20 SEM PHASE1 Email exchange with BSA, Sidley and 0.30 133.50 Old Republic Insurance regarding authorization for Kentucky defense counsel to review documents produced in discovery in the LFL cases and prepare for depositions. 07/15/20 SEM PHASE1 Email exchange with BSA regarding 0.30 133.50 Complaint and information obtained from the Suffolk County Council related to Porchenick-Allen case in review same. 07/15/20 SEM PHASE1 Email to BSA with information related 0.20 89.00 to Porchenick-Allen case in New York and follow-up with Suffolk County Council regarding the same. 07/15/20 SEM PHASE1 Review extensive reporting from 0.80 356.00 Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 34 of 88
Page 33 08/17/20 Bill No. 90257759 047657.000013-BAG
Date Initials Stage Description Hours Amount conference call discussing issues and strategy in bankruptcy matter and letter to TCC regarding the same. 07/15/20 SEM PHASE1 Additional email exchange with BSA 0.30 133.50 and Suffolk County Council regarding documents and information related to the Porchenick-Allen case in New York and continued investigation of the same. 07/15/20 SEM PHASE1 Review troop rosters received from 0.10 44.50 Suffolk County Council related to the Porchenick-Allen case in New York to confirm Plaintiff and perpetrator was in the same troop at the same time. 07/15/20 SEM PHASE1 Discuss content of local council 0.30 133.50 claims report and review final version of the same prior to sending to BSA for approval. 07/15/20 SEM PHASE1 Review documents received from 0.20 89.00 Iroquois Trail Council in New York related to Van Allen Spring lawsuit and forward same to BSA. 07/15/20 SEM PHASE1 Email to Iroquois Trail Council 0.10 44.50 regarding Van Allen Spring lawsuit notice to chartered organizations. 07/15/20 SEM PHASE1 Review documents and information 0.20 89.00 received from the Atlanta Area Council related to the AIS claims pending there. 07/15/20 SEM PHASE1 Email to Lincoln Heritage Council to 0.20 89.00 discuss possible deposition of Jason Pierce. 07/15/20 SEM PHASE1 Email exchange with Baden-Powell 0.30 133.50 Council regarding information and documents related to the Bob Blood AIS claim and review same. 07/15/20 SEM PHASE1 Email to Clint Scharf at the Three 0.20 89.00 Fires Council regarding his deposition in the Kentucky LFL lawsuit. 07/15/20 SEM PHASE1 Email exchange with Jason Pierce 0.20 89.00 regarding additional details related to Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 35 of 88
Page 34 08/17/20 Bill No. 90257759 047657.000013-BAG
Date Initials Stage Description Hours Amount his deposition and preparation in the Kentucky LFL case. 07/15/20 SEM PHASE1 Email exchange with Kentucky 0.20 89.00 defense counsel requesting them reach out to Danny Moore regarding his deposition in the LFL cases. 07/15/20 SEM PHASE1 Review email from Kentucky defense 0.10 44.50 counsel to Danny Moore regarding Plaintiff's request for his deposition. 07/15/20 SEM PHASE1 Review multiple emails from Axis 0.40 178.00 Capital to BSA and Plaintiff's counsel denying coverage for numerous abuse claims and lawsuits. 07/15/20 SEM PHASE1 Email exchange with Kentucky 0.20 89.00 defense counsel regarding discovery/status hearing today and affect on LFL. 07/15/20 SEM PHASE1 Receive and review letter from 0.10 44.50 Travelers Insurance of denial of coverage and partial disclaimer for 2020 New York claimants. 07/15/20 SEM PHASE1 Review new lawsuits filed in New 1.80 801.00 York and summarize same to send to local councils and New York defense counsel for investigation and assignment of the same. 07/15/20 SEM PHASE1 Telephone call from Clint Scharf 0.20 89.00 regarding setting his deposition and background regarding the same. 07/15/20 SEM PHASE1 Email exchange with Chief Seattle 0.30 133.50 Council regarding service of process on chartered organization (Bethel Grange) and handling of the notice of the same. 07/15/20 SEM PHASE1 Email exchange with Washington 0.20 89.00 State defense counsel to advise of service on Bethel Grange and need to include as a BSA Related Entity in the Notice of Second Consent Order extension. 07/15/20 SEM PHASE1 Email exchange with Seneca 0.20 89.00 Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 36 of 88
Page 35 08/17/20 Bill No. 90257759 047657.000013-BAG
Date Initials Stage Description Hours Amount Waterways Council in New York regarding new Francis K Feeney lawsuit and information related thereto. 07/15/20 SEM PHASE1 Review email from Seneca 0.30 133.50 Waterways Council in New York to BSA regarding new Francis K Feeney lawsuit and respond regarding contact with the chartered organization and update on further litigation matters. 07/15/20 SEM PHASE1 Review issue of John Carroll case 0.20 89.00 filed in New York but not received from the court and provide information regarding the same to Seneca Waterways Council. 07/15/20 SEM PHASE1 Review information related to the 0.20 89.00 deleted John Carroll case in New York and forward same to Seneca Waterways Council. 07/15/20 KAD PHASE1 Review rosters received from Atlanta 0.20 38.00 Area Council and email from Jason Baldridge regarding same. 07/15/20 KAD PHASE1 Review draft letter from Jessica 0.20 38.00 Boelter to James Stang regarding a rational path forward in the BSA's restructuring. 07/15/20 KAD PHASE1 Analyze lawsuit filed by Robert 0.20 38.00 Amitrano in preparation of entering same in Riskonnect. 07/15/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by Robert Amitrano. 07/15/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by Michael Porchenick- Allen. 07/15/20 KAD PHASE1 Analyze lawsuit filed by Michael 0.20 38.00 Porchenick-Allen in preparation of entering same in Riskonnect. 07/15/20 KAD PHASE1 Analyze lawsuit filed by Van Allen 0.20 38.00 Spring in preparation of entering Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 37 of 88
Page 36 08/17/20 Bill No. 90257759 047657.000013-BAG
Date Initials Stage Description Hours Amount same in Riskonnect. 07/15/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by Van Allen Spring. 07/15/20 KAD PHASE1 Analyze lawsuit filed by Robb 0.20 38.00 Cummings in preparation of entering same in Riskonnect. 07/15/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by Robb Cummings. 07/15/20 KAD PHASE1 Review email exchanges with 0.10 19.00 defense counsel and Anna Kutz regarding document review for KY Explorer cases. 07/15/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding complaint filed by Michael Porchenick-Allen. 07/15/20 KAD PHASE1 Prepare claims report for the Greater 0.80 152.00 New York Councils. 07/15/20 KAD PHASE1 Analyze lawsuit filed by Thomas 0.20 38.00 Kreiser in preparation of entering same in Riskonnect. 07/15/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by Thomas Kreiser. 07/15/20 KAD PHASE1 Review rosters received from the 0.20 38.00 Iroquois Trail Council in connection with the lawsuit filed by Van Allen Spring. 07/15/20 KAD PHASE1 Review email from Brittany Carlson 0.10 19.00 regarding summary of status conference in KY Explorer cases. 07/16/20 BAG PHASE1 Review and respond to email 0.30 192.00 exchange regarding filing of Consent Order in cases filed against the councils only. 07/16/20 BAG PHASE1 Review email from Anna Kutz 0.10 64.00 regarding claims asserted in Missouri. 07/16/20 BAG PHASE1 Initial review of Complaint in Wolfe v 0.50 320.00 Seneca Waterways Council and direct investigation regarding same. Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 38 of 88
Page 37 08/17/20 Bill No. 90257759 047657.000013-BAG
Date Initials Stage Description Hours Amount 07/16/20 BAG PHASE1 Review email from Oregon defense 0.20 128.00 counsel regarding notice received by charted organizations and attention to same. 07/16/20 BAG PHASE1 Review email and Complaint received 0.50 320.00 from the Scout Executives of Seneca Waterways Council. 07/16/20 SEM PHASE1 Email discussion with BSA regarding 0.30 133.50 information, documents and the complaint received in the lawsuit filed by Singhel related to perpetrator Pfleger in New York. 07/16/20 SEM PHASE1 Email exchange with Missouri 0.20 89.00 defense counsel regarding agreement to produce Ozark Trails Council asset information to Plaintiff I.G. in agreement for a withdraw of their objection in the bankruptcy case. 07/16/20 SEM PHASE1 Email exchange with Tim Anderson of 0.20 89.00 LFL regarding discussion about his deposition in the Kentucky Explorer case. 07/16/20 SEM PHASE1 Email exchange with Jason Pierce at 0.20 89.00 the Lincoln Heritage Council and Kentucky defense counsel regarding setting his deposition and preparation. 07/16/20 SEM PHASE1 Email exchange with New York 0.20 89.00 defense counsel regarding suggestion to file Entries of Appearance and Notices of Consent Orders in all lawsuits regardless of service. 07/16/20 SEM PHASE1 Email discussion with BSA regarding 0.30 133.50 New York defense counsel's request to file Entries of Appearance and Notices of Consent Order in all lawsuits regardless of service. 07/16/20 SEM PHASE1 Email to Sidley team with New York 0.20 89.00 defense counsel's suggestion to file Entries of Appearance and Notices of Consent Orders in all lawsuits Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 39 of 88
Page 38 08/17/20 Bill No. 90257759 047657.000013-BAG
Date Initials Stage Description Hours Amount regardless of service and background of reasoning and discussion with BSA about the same. 07/16/20 SEM PHASE1 Telephone call from New York 0.10 44.50 defense counsel to further discuss rationale behind suggestion to file Entries of Appearance and Notices of Consent Orders in all cases. 07/16/20 SEM PHASE1 Follow-up email exchange with BSA 0.20 89.00 regarding second notice of Claim for Redacted in North Carolina. 07/16/20 SEM PHASE1 Email exchange between BSA to 0.20 89.00 Missouri defense counsel regarding Redacted Worker's Compensation lawsuit filed against the St. Louis Area Council. 07/16/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 Redacted Worker's Compensation lawsuit filed against the St. Louis Area Council. 07/16/20 SEM PHASE1 Email exchange with Sidley regarding 0.20 89.00 direction for filing Notices of Consent Order in New York lawsuits. 07/16/20 SEM PHASE1 Email exchange with BSA advising of 0.20 89.00 service of Norman Wolfe lawsuit on the Seneca Waterways Council. 07/16/20 SEM PHASE1 Email to New York defense counsel 0.10 44.50 to advise of service in the Norman Wolfe lawsuit on the Seneca Waterways Council and direction to file Notice of Consent Order. 07/16/20 SEM PHASE1 Email discussion with Oregon 0.30 133.50 defense counsel regarding notices being sent to chartered organizations regarding the reporting of BSA abuse claims in the bankruptcy process. 07/16/20 SEM PHASE1 Email exchange with BSA and Sidley 0.30 133.50 to confirm Washington State defense counsel has been added to the list of ordinary course professionals for billing and payment purposes. Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 40 of 88
Page 39 08/17/20 Bill No. 90257759 047657.000013-BAG
Date Initials Stage Description Hours Amount 07/16/20 SEM PHASE1 Review assignment of new Feeney 0.20 89.00 lawsuit in New York based on the year of alleged abuse and related insurance issue. 07/16/20 SEM PHASE1 Email exchange with Clint Scharff 0.30 133.50 and Kentucky defense counsel regarding concerns related to his deposition and preparation. 07/16/20 SEM PHASE1 Email to Kentucky defense counsel 0.10 44.50 regarding the logistics of the LFL depositions. 07/16/20 SEM PHASE1 Further email exchange with Sidley 0.20 89.00 regarding strategy for responding to filed, but unserved lawsuits in New York. 07/16/20 SEM PHASE1 Send request for search of BSA 0.10 44.50 internal files pertaining to alleged perpetrators in the newly filed New York lawsuits for review prior to sending cases to local councils. 07/16/20 SEM PHASE1 Email from Clint Scharff regarding 0.20 89.00 dates he can be available for deposition and prep and forward same to BSA and Sidley. 07/16/20 SEM PHASE1 Email exchange with Kentucky 0.20 89.00 defense counsel regarding request to BSA for travel to appear live for LFL depositions. 07/16/20 SEM PHASE1 Email to BSA with request to approve 0.20 89.00 travel for Kentucky defense counsel live appearance at LFL depositions. 07/16/20 SEM PHASE1 Review BSA internal files for alleged 0.80 356.00 perpetrators in newly filed New York lawsuits and summarize same for information to send to local councils. 07/16/20 SEM PHASE1 Draft emails to New York local 0.10 44.50 councils with new lawsuits and summaries for search of documents and information related to the same. 07/16/20 SEM PHASE1 Telephone call from Black Swamp 0.20 89.00 Area Council to discuss research and Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 41 of 88
Page 40 08/17/20 Bill No. 90257759 047657.000013-BAG
Date Initials Stage Description Hours Amount findings related to AIS claims inquiry. 07/16/20 SEM PHASE1 Email discussion with New York 0.30 133.50 defense counsel regarding court ordered preliminary conferences for several new BSA abuse cases (some not served). 07/16/20 SEM PHASE1 Email from BSA with newly served 0.30 133.50 lawsuit in California and calculate 180 day service time period for explanation of the same. 07/16/20 SEM PHASE1 Review new lawsuit in California for 0.40 178.00 Marcus Nelson and summarize the same for the California Inland Empire Council. 07/16/20 SEM PHASE1 Email to California Inland Empire 0.50 222.50 Council regarding Marcus Nelson lawsuit and investigation into the same. 07/16/20 SEM PHASE1 Email to New York defense counsel 0.20 89.00 regarding strategy to begin filing Notices of Consent Order in all new lawsuits. 07/16/20 SEM PHASE1 Further email exchange with New 0.20 89.00 York defense counsel regarding inclusion of chartered organizations in the Notice of Consent Orders being filed. 07/16/20 SEM PHASE1 Review troop rosters and prior 0.40 178.00 investigation notes to determined improper service on wrong council in Nelson Marcus case filed in California and alert council and BSA to the same. 07/16/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding Complaint filed by Timothy Singhel. 07/16/20 KAD PHASE1 Review 28-page tender letter from 0.30 57.00 Travelers. 07/16/20 KAD PHASE1 Analyze 34 coverage letters from 0.60 114.00 AXIS in connection with various New Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 42 of 88
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Date Initials Stage Description Hours Amount York claims. 07/16/20 KAD PHASE1 Email exchange with Anna Kutz 0.10 19.00 regarding entering Redacted claim into Riskonnect. 07/16/20 KAD PHASE1 Review email exchange between 0.10 19.00 Bruce Griggs and Sidley Austin regarding Washington defense counsel and confirming same is listed as an ordinary course professional. 07/16/20 KAD PHASE1 Analyze rosters received from the 0.30 57.00 Local Council in connection with the lawsuit filed by Francis Feeney. 07/16/20 KAD PHASE1 Analyze lawsuit filed by PC-6 Doe in 0.20 38.00 preparation of entering same in Riskonnect. 07/16/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by PC-6 Doe. 07/16/20 KAD PHASE1 Analyze lawsuit filed by Ingrid Kelly in 0.20 38.00 preparation of entering same in Riskonnect. 07/16/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by Ingrid Kelly. 07/16/20 KAD PHASE1 Analyze BSA's internal files and 1.20 228.00 search for alleged perpetrators named in six new lawsuits filed in New York. 07/17/20 BAG PHASE1 Review letter from inmate Chris 0.20 128.00 Arguelles regarding abuse allegations and attention to same. 07/17/20 BAG PHASE1 Review/analyze multiple new 1.50 960.00 California Complaints and work on assignment of defense counsel. 07/17/20 SEM PHASE1 Email from Chief Seattle Council with 0.30 133.50 documents and files pertaining to all pending abuse matters there and review same. 07/17/20 SEM PHASE1 Email from C.N.A. Insurance 0.10 44.50 regarding coverage claims for multiple abuse matters around the Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 43 of 88
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Date Initials Stage Description Hours Amount United States. 07/17/20 SEM PHASE1 Email from Hawaii defense counsel 0.10 44.50 with update on communications with attorney for John Roes 1-8 regarding claim details. 07/17/20 SEM PHASE1 Email from Black Swamp Area 0.20 89.00 Council with documents and information related to request for BSA internal material in AIS claims and review the same. 07/17/20 SEM PHASE1 Email from BSA with notice of new 0.10 44.50 claim for Chris Arguelles in prison. 07/17/20 SEM PHASE1 Continue drafting emails to New York 0.60 267.00 local councils with new lawsuits and requests for information from the same. 07/17/20 SEM PHASE1 Email to New York defense counsel 0.30 133.50 to assign new lawsuits for defense and filing of Notices of Consent Order. 07/17/20 SEM PHASE1 Draft chart of all pending California 1.30 578.50 lawsuits for tracking and investigation of the same. 07/17/20 SEM PHASE1 Review and analyze California 0.20 89.00 defense counsel for assignment of newly served lawsuits there. 07/17/20 SEM PHASE1 Review email and correspondence 0.10 44.50 received from BSA excess insurance carrier, Everest Insurance, regarding Fye case filed in New York and reservation of rights related to the same. 07/17/20 SEM PHASE1 Email to Sidley regarding orders 0.10 44.50 entered from July 9th hearing. 07/17/20 SEM PHASE1 Email from BSA regarding service of 0.20 89.00 process on BSA National in PC-11 DOE case filed in New York and forward same to local defense counsel with direction to file Notice of Consent Order. Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 44 of 88
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Date Initials Stage Description Hours Amount 07/17/20 SEM PHASE1 Draft comprehensive claims chart for 2.30 1,023.50 all recently received New York lawsuits to consolidate data into a single source. 07/17/20 SEM PHASE1 Review Weekly New Claims Report 0.10 44.50 to ensure all new claims have been addressed. 07/17/20 SEM PHASE1 Email exchange with Aloha Council 0.20 89.00 regarding total number of claims and lawsuits pending in Guam and Hawaii. 07/17/20 SEM PHASE1 Review news stories related to BSA 0.30 133.50 abuse arrest and bankruptcy matters. 07/17/20 SEM PHASE1 Email exchange with Tim Anderson at 0.20 89.00 LFL regarding setting a time to discuss his pending deposition. 07/17/20 KAD PHASE1 Email exchange with Anna Kutz 0.10 19.00 regarding claim file for Redacted Redacted. 07/17/20 KAD PHASE1 Review completed service of process 0.10 19.00 on California Inland Empire Council in connection with the lawsuit filed by Marcus Nelson and review email from Matt Myers regarding same. 07/17/20 KAD PHASE1 Update claim record in Riskonnect to 0.10 19.00 reflect service completed upon California Inland Empire Council in connection with the Lawsuit filed by Marcus Nelson. 07/17/20 KAD PHASE1 Review completed service of process 0.10 19.00 on Seneca Waterways Council in connection with the lawsuit filed by Norman Wolfe and review email from Tiffany Drum regarding same. 07/17/20 KAD PHASE1 Update claim record in Riskonnect to 0.10 19.00 reflect service completed upon Seneca Waterways Council in connection with the Lawsuit filed by Norman Wolfe. 07/17/20 KAD PHASE1 Review CNA tender letter regarding 0.10 19.00 Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 45 of 88
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Date Initials Stage Description Hours Amount Marsh Law Firm plaintiffs. 07/17/20 KAD PHASE1 Email exchange with Nicole 0.10 19.00 Liberatore regarding notices of second stipulation and agreed order filed in 5 new, New York lawsuits. 07/17/20 KAD PHASE1 Prepare weekly new claims report. 2.10 399.00 07/17/20 KAD PHASE1 Compile California case information 0.40 76.00 to assist attorney with assigning newly served cases to defense counsel. 07/17/20 KAD PHASE1 Email Sidley Austin, Alvarez Marsal, 0.10 19.00 BSA and Monica Blacker regarding weekly new abuse claims report. 07/17/20 KAD PHASE1 Analyze Troop rosters received from 0.30 57.00 the Black Swamp Area Council in connection with the AIS claims and review email from Marc Kogan regarding same. 07/17/20 KAD PHASE1 Email exchange with Lynn 0.10 19.00 Richardson regarding receipt of Order to Show Cause with Temporary Restraining Order filed in PC-11 Doe case. 07/17/20 KAD PHASE1 Analyze lawsuit filed by Nelson Cruz 0.20 38.00 in preparation of entering same in Riskonnect. 07/17/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by Nelson Cruz. 07/20/20 BAG PHASE1 Review and respond to email from 0.10 64.00 defense counsel regarding JMB Doe v. Greater St. Louis Area Council. 07/20/20 BAG PHASE1 Review email from Thomas Oates at 0.10 64.00 Sidley Austin regarding revised schedule 2. 07/20/20 BAG PHASE1 Review email from Bill Curtain at 0.20 128.00 Sidley Austin proposed lift stay order in the Cote v BSA matter and attention to same. 07/20/20 BAG PHASE1 Review Complaint and email 0.20 128.00 Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 46 of 88
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Date Initials Stage Description Hours Amount exchanges regarding J.A. and S.A. v Theodore Roosevelt Council and attention to same. 07/20/20 BAG PHASE1 Review/analyze memorandum and 1.00 640.00 chart regarding all New York lawsuits and internal communications with Sean Manning regarding same. 07/20/20 BAG PHASE1 Review /analyze chart and 0.50 320.00 memorandum regarding all California cases and internal communications with Sean Manning regarding same. 07/20/20 BAG PHASE1 Internal conferences with Sean 1.00 640.00 Manning and Kelci Davis regarding pending claims and cases. 07/20/20 SEM PHASE1 Review data regarding Hawaii and 0.20 89.00 Guam pre-litigation claims and filed lawsuits and send same to Aloha Council per their request. 07/20/20 SEM PHASE1 Email exchange with Kentucky 0.30 133.50 defense counsel in the LFL cases regarding Defendant Schmidt filing her Motion for Summary Judgment in the Redacted case and briefly review same. 07/20/20 SEM PHASE1 Review new lawsuit for J.A. and S.A. 0.30 133.50 filed in New York and summarize same for the Theodore Roosevelt Council. 07/20/20 SEM PHASE1 Email to Theodore Roosevelt Council 0.30 133.50 with notice of new lawsuit filed in New York for J.A. and S.A. 07/20/20 SEM PHASE1 Email to New York defense counsel 0.20 89.00 regarding assignment of new lawsuit against BSA and the Theodore Roosevelt Council in New York for J.A. and S.A. 07/20/20 SEM PHASE1 Email exchange with Longhouse 0.20 89.00 Council regarding service on the Council in the PC-11 DOE case. 07/20/20 SEM PHASE1 Continue reviewing spreadsheet of 2.80 1,246.00 claims and perpetrators not in BSA's Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 47 of 88
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Date Initials Stage Description Hours Amount internal files and collect information to send to councils seeking documents and information for adding to BSA internal files. 07/20/20 SEM PHASE1 Further email exchange with Aloha 0.30 133.50 Council regarding the total number of claims settled in Guam and Hawaii and gather information for the same. 07/20/20 SEM PHASE1 Email from Sidley regarding changes 0.10 44.50 to BSA bankruptcy team for all further correspondence. 07/20/20 SEM PHASE1 Emails from BSA with additional 0.20 89.00 information related to investigation of Complaint filed by Stephen Snider in New York. 07/20/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 Complaint filed by John Welch filed in New York and communication with local council regarding the same. 07/20/20 SEM PHASE1 Email exchange with Sidley regarding 0.40 178.00 revisions to Schedule 2 of the BSA Bankruptcy Consent Order, review said Schedule 2 and discuss the same. 07/20/20 SEM PHASE1 Begin sending emails to local 3.80 1,691.00 councils beginning with the letter "C" seeking information to use and add to BSA internal files for multi-claimant matters. 07/20/20 SEM PHASE1 Email from the Theodore Roosevelt 0.20 89.00 Council in New York with information related to the J.A. and S.A. case and review the same. 07/20/20 SEM PHASE1 Review emails from Everest 0.10 44.50 Insurance to BSA denying coverage for certain claims as outside the policy period. 07/20/20 SEM PHASE1 Email discussion with Missouri 0.30 133.50 defense counsel regarding the Court's order for a Response to Plaintiff's Motion to Remand in the Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 48 of 88
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Date Initials Stage Description Hours Amount John Doe case. 07/20/20 SEM PHASE1 Email from Missouri defense counsel 0.30 133.50 with draft of status report to file with court in John Doe case in lieu of response to Motion for Remand, review same, and approve for filing. 07/20/20 SEM PHASE1 Email exchange with the Greater New 0.20 89.00 York Councils regarding independence of the five borough councils under them. 07/20/20 KAD PHASE1 Calculate the total number of claims 1.00 190.00 and lawsuits pending in Hawaii and Guam separately per the request of the Aloha Council Scout Executive. 07/20/20 KAD PHASE1 Analyze lawsuit filed by PC-11 Doe in 0.20 38.00 preparation of entering same in Riskonnect. 07/20/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by PC-11 Doe. 07/20/20 KAD PHASE1 Analyze lawsuit filed by William 0.20 38.00 Wreden in preparation of entering same in Riskonnect. 07/20/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by William Wreden. 07/20/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by Stephen Snider. 07/20/20 KAD PHASE1 Analyze lawsuit filed by Stephen 0.20 38.00 Snider in preparation of entering same in Riskonnect. 07/20/20 KAD PHASE1 Search BSA's internal files for alleges 0.20 38.00 perpetrator named in J.A. and S.A. (NY) lawsuit. 07/20/20 KAD PHASE1 Analyze lawsuit filed by John Welch 0.20 38.00 in preparation of entering same in Riskonnect. 07/20/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by John Welch. 07/20/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 49 of 88
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Date Initials Stage Description Hours Amount regarding lawsuit filed by Stephen Snider and request for information to the Council regarding same. 07/20/20 KAD PHASE1 Calculate the number of settled 0.20 38.00 Guam and Hawaii claims separately. 07/20/20 KAD PHASE1 Email exchange with Thomas Oates 0.10 19.00 regarding revisions needed to Schedule 2 BSA Related Parties. 07/20/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding Complaint filed by John Welch and request for information to the Council regarding same. 07/20/20 KAD PHASE1 Revise Schedule 2 List of BSA 0.90 171.00 Related Parties. 07/20/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding Complaint filed by William Wreden. 07/20/20 KAD PHASE1 Communicate with Anna Kutz via 0.10 19.00 Chatter regarding status of D.W. (NJ) pre-litigation claim and updating Riskonnect with same. 07/20/20 KAD PHASE1 Communicate with Anna Kutz via 0.10 19.00 Chatter regarding status of Rocco Viviani lawsuit and updating Riskonnect with same. 07/21/20 BAG PHASE1 Review email from Steve McGowan 0.20 128.00 and attached Motion to Remand in the Doe v BSA matter (NY) and internal communications with Sean Manning and Kelci Davis regarding same. 07/21/20 BAG PHASE1 Review email from Karim Basaria at 0.20 128.00 Sidley Austin regarding New York cases and attention to same. 07/21/20 BAG PHASE1 Email to defense counsel regarding 0.10 64.00 motion to remand in Doe v BSA (NY). 07/21/20 BAG PHASE1 Internal team meeting and 1.50 960.00 communications to discuss new claims and pending tasks to be completed. Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 50 of 88
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Date Initials Stage Description Hours Amount 07/21/20 SEM PHASE1 Email received from Capitol Area 0.20 89.00 Council with information and documents related to BSA internal creation project and review same. 07/21/20 SEM PHASE1 Email received from Cape Fear 0.20 89.00 Council with information and documents related to BSA internal creation project and review same. 07/21/20 SEM PHASE1 Email received from Chickasaw 0.20 89.00 Council with information and documents related to the BSA internal creation project and review same. 07/21/20 SEM PHASE1 Email from Sidley with proposed 0.30 133.50 order to lift stay in the Cote case in New Hampshire review same and send to local defense counsel for review. 07/21/20 SEM PHASE1 Email received from Choctaw Area 0.10 44.50 Council with information related to BSA internal creation project and review same. 07/21/20 SEM PHASE1 Email received from Circle Ten 0.10 44.50 Council with information and documents related to BSA internal creation project and review same. 07/21/20 SEM PHASE1 Additional email received from 0.20 89.00 Choctaw Area Council with information and documents related to BSA internal creation project and review same. 07/21/20 SEM PHASE1 Multiple emails from the Blue 0.40 178.00 Mountain Council with documents and information related to the BSA internal creation project, review same and forward all to BSA. 07/21/20 SEM PHASE1 Email exchange with BSA and the 0.20 89.00 Cherokee Area Council #469 regarding council misidentification in BSA internal creation project and correction of the same. Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 51 of 88
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Date Initials Stage Description Hours Amount 07/21/20 SEM PHASE1 Email received from proper Cherokee 0.10 44.50 Area Council with information related to the BSA internal creation project and review same. 07/21/20 SEM PHASE1 Email from Cascade Pacific Council 0.10 44.50 regarding investigation of BSA internal creation project claims. 07/21/20 SEM PHASE1 Email from Baltimore Area Council 0.10 44.50 with information related to BSA internal creation project and review same. 07/21/20 SEM PHASE1 Email exchange with Coastal 0.20 89.00 Carolina Council regarding change in council leadership and investigation of BSA internal file project claims. 07/21/20 SEM PHASE1 Email exchange with the Far East 0.20 89.00 Council in response to request for information related to BSA internal file project claims. 07/21/20 SEM PHASE1 Review news story regarding Pine 0.20 89.00 Tree Council in Maine selling its camp site and send same to BSA. 07/21/20 SEM PHASE1 Email from New Hampshire defense 0.20 89.00 counsel approving of draft order to file in the bankruptcy case related to dismissal of the Cote case and forward approvals from all to Sidley. 07/21/20 SEM PHASE1 Review email received from the Bay 0.20 89.00 Area Council with information and documents related to BSA internal creation project and review same. 07/21/20 SEM PHASE1 Review BSA internal files located for 1.60 712.00 alleged perpetrators covered by the BSA internal file project to determine if they are the same person. 07/21/20 SEM PHASE1 Email from Chief Seattle Council 0.10 44.50 regarding change of council leadership and investigation into BSA internal file project claims. 07/21/20 SEM PHASE1 Email from Colonial Virginia Council 0.10 44.50 regarding a lack of information related Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 52 of 88
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Date Initials Stage Description Hours Amount to the BSA internal file project claims. 07/21/20 SEM PHASE1 Review Motion to Remand issue in 0.30 133.50 the John Doe New York case filed in the Northern District of New York and discuss same with local defense counsel. 07/21/20 SEM PHASE1 Email discussion with Sidley 0.30 133.50 regarding Plaintiff's notice of inadvertent filing lawsuits including BSA as a Defendant and their intent to file amended complaints. 07/21/20 SEM PHASE1 Continue drafting emails to local 0.60 267.00 councils beginning with the letter "C" relevant to the BSA internal file project investigation. 07/21/20 SEM PHASE1 Continue to review spreadsheet of 1.20 534.00 perpetrators not in BSA's internal files for information to add to chart and send to local councils seeking additional materials for creation of same. 07/21/20 SEM PHASE1 Telephone call with Connecticut 0.20 89.00 Yankee Council regarding mis-filed lawsuit brought in New York and handling of the same. 07/21/20 SEM PHASE1 Continue drafting emails to local 1.00 445.00 councils beginning with the letter "D" relevant to the BSA internal file project investigation. 07/21/20 SEM PHASE1 Email exchange with New Jersey 0.20 89.00 defense counsel regarding filed Second Notice of Entry in the Jack Doe matter, potential for Plaintiff to seek a stipulation in the Jack MM Doe matter and administrative dismissals of several other pending state court matters. 07/21/20 SEM PHASE1 Review email received from the Chief 0.20 89.00 Seattle Council with information and documents related to BSA internal file creation project, review same and send to BSA. Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 53 of 88
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Date Initials Stage Description Hours Amount 07/21/20 SEM PHASE1 Review email received from the 0.20 89.00 Cascade Pacific Council with information and documents related to BSA internal file creation project and review same. 07/21/20 SEM PHASE1 Review email received from the 0.10 44.50 Daniel Boone Council advising they have no documents or information related to BSA internal file creation project. 07/21/20 SEM PHASE1 Review email received from the 0.20 89.00 Chippewa Valley Council with information and documents related to BSA internal file creation project and review same. 07/21/20 SEM PHASE1 Review email received from the 0.20 89.00 Catalina Council with information and documents related to BSA internal file creation project and review same. 07/21/20 SEM PHASE1 Review email received from the 0.20 89.00 Redwood Empire Council with information and documents related to BSA internal file creation project and review same. 07/21/20 SEM PHASE1 Extensive email discussion with 0.60 267.00 Crater Lake Council regarding information and documents related to BSA internal file project investigation, the search for said records, and review of the same. 07/21/20 KAD PHASE1 Email exchange with William Curtain 0.10 19.00 regarding further abuse actions for bankruptcy court. 07/21/20 KAD PHASE1 Communicate with Anna Kutz via 0.10 19.00 Chatter regarding the status of the Albert Opacity lawsuit and updating Riskonnect with same. 07/21/20 KAD PHASE1 Update litigation section in 0.10 19.00 Riskonnect for Albert Opacity lawsuit per Anna Kutz's request. 07/21/20 KAD PHASE1 Update litigation section in 0.10 19.00 Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 54 of 88
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Date Initials Stage Description Hours Amount Riskonnect for Peter Renwick lawsuit per Anna Kutz's request. 07/21/20 KAD PHASE1 Communicate with Anna Kutz via 0.10 19.00 Chatter regarding the status of the Peter Renwick lawsuit and updating Riskonnect with same. 07/21/20 KAD PHASE1 Search BSA's internal files for three 0.30 57.00 of the alleged perpetrators named in AIS claims. 07/21/20 KAD PHASE1 Calculate the total number of lawsuits 0.20 38.00 filed in New York. 07/22/20 BAG PHASE1 Review email from defense counsel 0.20 128.00 regarding defendant's response to plaintiff's Motion to Compel in Redacted v BSA and attention to same. 07/22/20 BAG PHASE1 Review email and attached 0.20 128.00 complaints received from Karim Basaria at Sidley Austin regarding New York cases and attention to same. 07/22/20 BAG PHASE1 Review and respond to email from 0.20 128.00 Thomas Oates at Sidley Austin regarding subsidiary councils in New York city. 07/22/20 BAG PHASE1 Review new complaints in New York 0.30 192.00 and request for information from Chubb and attention to same. 07/22/20 BAG PHASE1 Review email status update from 0.10 64.00 defense counsel in Long v BSA. 07/22/20 BAG PHASE1 Review and respond to email from 0.20 128.00 Paul Needham at Aspen Insurance regarding John Doe I (Minor) v BSA (Ohio). 07/22/20 BAG PHASE1 Work on assessment and evaluation 4.50 2,880.00 of 64 new claims. 07/22/20 SEM PHASE1 Email exchange with Sidley regarding 0.20 89.00 the independence of the five New York borough councils in relationship to the Greater New York Councils. Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 55 of 88
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Date Initials Stage Description Hours Amount 07/22/20 SEM PHASE1 Telephone call with Greater New 0.20 89.00 York Councils regarding relationship with, and independence of, the five borough councils. 07/22/20 SEM PHASE1 Email from Crater Lake Council 0.10 44.50 regarding update on process of locating records related to the BSA internal file project information request. 07/22/20 SEM PHASE1 Email exchange with Sidley regarding 0.20 89.00 four New York cases being amended by Plaintiff's counsel to drop BSA as a defendant and for need to notify local defense counsel. 07/22/20 SEM PHASE1 Review four New York lawsuits being 0.30 133.50 amended by Plaintiff's counsel to determine proper defense counsel to notify. 07/22/20 SEM PHASE1 Emails to New York Defense counsel 0.20 89.00 to notify of pending amended complaints and need to hold off on filing Notices and Entries of Appearance. 07/22/20 SEM PHASE1 Email from BSA with correspondence 0.40 178.00 from Chubb Insurance regarding their coverage position on the Robert Bartoli case filed in New York against the Hudson Valley Council, review the same and respond to BSA. 07/22/20 SEM PHASE1 Email from Kentucky defense counsel 0.10 44.50 regarding receipt and upload of several new documents related to Plaintiff Redacted in the LFL cases. 07/22/20 SEM PHASE1 Email from New Mexico defense 0.20 89.00 counsel with co-defendant Richard Lucero's Response to Plaintiff's Motion to Compel and review same. 07/22/20 SEM PHASE1 Email to Haynes and Boone 0.20 89.00 regarding Chubb letter seeking information related to the Robert Bartoli lawsuit in New York and input Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 56 of 88
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Date Initials Stage Description Hours Amount on a response to the same. 07/22/20 SEM PHASE1 Review claims report of matters 0.20 89.00 currently pending against the Crater Lake Council in Oregon and email same to the council per their request. 07/22/20 SEM PHASE1 Email from Missouri defense counsel 0.20 89.00 regarding effect of status report to court staying John Doe lawsuit until November 16, 2020 and review said Court Order. 07/22/20 SEM PHASE1 Email from BSA advising that we do 0.10 44.50 not need to respond to Chubb letter related to Robert Bartoli case in New York. 07/22/20 SEM PHASE1 Email exchange with New Jersey 0.20 89.00 defense counsel regarding hearing setting hearing on Co-Defendant's motion for a definitive statement in the Luis Lopez case and appearance at the same. 07/22/20 SEM PHASE1 Review email exchange from Aspen 0.20 89.00 Insurance seeking status in information related to John Doe case filed in Ohio and response to the same. 07/22/20 SEM PHASE1 Draft and send emails to the local 0.90 400.50 councils beginning with the letters "E" and "F" seeking information for the BSA internal file project. 07/22/20 SEM PHASE1 Email exchange with Kentucky 0.20 89.00 defense counsel regarding Court Order entered from last week's status conference regarding continued stay, next conference and order to submit a settlement statement by October 13, 2020 and review the same. 07/22/20 SEM PHASE1 Email exchange with Northern New 0.20 89.00 Jersey Council regarding service of process in the Cornelius Kennelly O'Connell lawsuit. 07/22/20 SEM PHASE1 Review New Jersey lawsuit for 0.50 222.50 Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 57 of 88
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Date Initials Stage Description Hours Amount Cornelius Kennelly O'Connell filed against the Northern New Jersey Council and compare to previously received letter of representation. 07/22/20 SEM PHASE1 Assign new lawsuit filed in New 0.10 44.50 Jersey for Cornelius Kennelly O'Connell to local defense counsel. 07/22/20 SEM PHASE1 Email exchange with Blue Ridge 0.30 133.50 Mountains Council regarding documents and information related to BSA internal file project and review the same. 07/22/20 SEM PHASE1 Continue to review spreadsheet of 1.50 667.50 multi-claimant for perpetrators not in BSA's internal files and collect data to send to local BSA councils seeking materials to create same. 07/22/20 SEM PHASE1 Email exchange with Erie Shores 0.20 89.00 Council regarding prior investigation into BSA internal file project claims and request to send said information and documents. 07/22/20 SEM PHASE1 Review email from Chattahoochee 0.20 89.00 Council with information and documents related to BSA internal file project search and review the same. 07/22/20 SEM PHASE1 Review emails from Allianz 0.10 44.50 Resolution Management with reservations of rights letters for New York and non-New York claims. 07/22/20 SEM PHASE1 Review email from Erie Shores 0.20 89.00 Council with information and documents related to BSA internal file project claims and review same. 07/22/20 SEM PHASE1 Review notice of eight new lawsuits 0.10 44.50 filed in New York this week. 07/22/20 KAD PHASE1 Communicate with Jennifer Nichols 0.10 19.00 via Chatter regarding alleged perpetrator, Irving Schroder's file,. 07/22/20 KAD PHASE1 Email exchange with Kathleen 0.10 19.00 Russell regarding Defendant's Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 58 of 88
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Date Initials Stage Description Hours Amount Response to Plaintiff's First Motion to Compel Discovery. 07/22/20 KAD PHASE1 Review email from Cassie Brown 0.10 19.00 regarding UPS employment records for B.L. 07/22/20 KAD PHASE1 Prepare Crater Lake Council claims 0.40 76.00 report. 07/22/20 KAD PHASE1 Analyze lawsuit filed by Francis 0.20 38.00 Feeney in preparation of entering same in Riskonnect. 07/22/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by Francis Feeney. 07/22/20 KAD PHASE1 Email exchange with Robyn Jungers 0.10 19.00 regarding cost center to use when entering claims in Riskonnect. 07/22/20 KAD PHASE1 Email exchange with BSA regarding 0.30 57.00 search for a settlement agreement from a historical case (A.S. (PA)). 07/22/20 KAD PHASE1 Prepare report of new claims to assist 2.90 551.00 attorney with valuing and rating same. 07/22/20 KAD PHASE1 Analyze lawsuit filed by Michael 0.20 38.00 Sinsel, Jr. in preparation of entering same in Riskonnect. 07/22/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by Michael Sinsel, Jr. 07/22/20 KAD PHASE1 Review email from Hassan Popal 0.10 19.00 regarding court scheduling oral argument on co-defendant's motion for a definitive statement. 07/23/20 BAG PHASE1 Review tender of defense letter in 0.20 128.00 Lopez v BSA (NJ) and exchange email with Anna Kutz regarding same. 07/23/20 BAG PHASE1 Review email from Georgia defense 0.20 128.00 counsel regarding potential conflict of interest and attention to same. 07/23/20 BAG PHASE1 Telephone conference with Anna 0.20 128.00 Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 59 of 88
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Date Initials Stage Description Hours Amount Kutz regarding the Cote v BSA matter and tender of defense by the Town of Deerfield. 07/23/20 SEM PHASE1 Email exchange with Kentucky 0.20 89.00 defense counsel regarding inability to get dates for Tim Anderson deposition and need to continue efforts for the same. 07/23/20 SEM PHASE1 Review email from Blue Ridge 0.20 89.00 Mountains Council with information and documents related to BSA internal file project and review the same. 07/23/20 SEM PHASE1 Review eight new lawsuits filed in 1.60 712.00 New York this week and gather information for litigation tracking chart. 07/23/20 SEM PHASE1 Telephone call with Tim Anderson to 0.20 89.00 discuss his potential deposition and background for the same. 07/23/20 SEM PHASE1 Email from Tim Anderson with dates 0.20 89.00 for his deposition and preparation for the same and forward same to Kentucky defense counsel and Sidley. 07/23/20 SEM PHASE1 Review email from BSA regarding 0.20 89.00 request for a project to compile all council specific claims data including OMNI claims and discuss same with BSA team. 07/23/20 SEM PHASE1 Email to all local BSA councils with 0.80 356.00 new lawsuits and summary of the same with requests for information related to the same. 07/23/20 SEM PHASE1 Emails to New York defense counsel 0.30 133.50 to assign new lawsuits filed there. 07/23/20 SEM PHASE1 Telephone call with Connecticut 0.20 89.00 Rivers Council regarding research and findings related to BSA internal file project claims. 07/23/20 SEM PHASE1 Request BSA internal files for all 0.30 133.50 Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 60 of 88
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Date Initials Stage Description Hours Amount alleged perpetrators in newly filed New York lawsuits and review found files to summarize for council research purposes. 07/23/20 SEM PHASE1 Email from Cornhusker Council 0.10 44.50 regarding a lack of records in response to the BSA internal file project request due to a fire at the council offices. 07/23/20 SEM PHASE1 Review email from Buckskin Council 0.20 89.00 with information and documents in response to BSA internal file project request and review the same. 07/23/20 SEM PHASE1 Email exchange with Garden State 0.20 89.00 Council regarding tender of defense for perpetrator in the Lopez case. 07/23/20 SEM PHASE1 Review and discuss with BSA, the 0.20 89.00 tender of defense letter in the Lopez case in New Jersey and response to the same. 07/23/20 SEM PHASE1 Review email from Dan Beard 0.20 89.00 Council with information and documents received in response to BSA internal file project request and review the same. 07/23/20 SEM PHASE1 Continue reviewing spreadsheet of 2.70 1,201.50 multi-claimant claims eith perpetrators not in BSA internal files and continue compiling data for spreadsheet to send to local BSA councils seeking information in support of BSA internal file creation. 07/23/20 SEM PHASE1 Telephone call with Coastal Georgia 0.50 222.50 Council to discuss information related to multiple BSA internal file project claims and background of council and records management issues. 07/23/20 SEM PHASE1 Email from Kentucky defense counsel 0.20 89.00 regarding request to use Relativity for an extensive set of records for review in the LFL cases in connection to continued discovery and forward Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 61 of 88
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Date Initials Stage Description Hours Amount same to BSA for approval. 07/23/20 SEM PHASE1 Email discussion with Georgia 0.30 133.50 defense counsel and BSA regarding Georgia law firm being retained for representation of Travelers Insurance in the Hartford adversary proceeding against BSA in Delaware. 07/23/20 SEM PHASE1 Review email from Connecticut 0.20 89.00 Rivers Council with information and documents related to BSA internal file project request, review and send same to BSA. 07/23/20 SEM PHASE1 Email exchange with Greater Niagara 0.20 89.00 Frontier Council regarding research into BSA internal file project request and difficulties in doing the same. 07/23/20 SEM PHASE1 Email from Iroquois Trails Council in 0.10 44.50 New York regarding information related to the newly filed Peter Jones lawsuit. 07/23/20 SEM PHASE1 Review and respond to request form 0.20 89.00 BSA regarding information related to the Cote case in New Hampshire for settlement purposes. 07/23/20 SEM PHASE1 Email from BSA with information 0.10 44.50 obtained from the Suffolk County Council in regard to the new Porchenick-Allen lawsuit filed in New York. 07/23/20 SEM PHASE1 Email discussion with BSA and 0.30 133.50 Connecticut defense counsel regarding status, tender of defense and requests for indemnity in the Jane Doe v. Town of Trumbull case. 07/23/20 SEM PHASE1 Research Jane Doe v. Town of 0.20 89.00 Trumbull case and advise BSA of not finding any tender of defense or request for indemnity by the Town. 07/23/20 SEM PHASE1 Research Jane Doe v. Town of 0.20 89.00 Trumbull file for evidence confirming the Town was the sponsoring Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 62 of 88
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Date Initials Stage Description Hours Amount organization and send same to BSA. 07/23/20 KAD PHASE1 Analyze Complaint filed by Cornelius 0.20 38.00 Kennelly O'Connell in preparation of updating Riskonnect with same. 07/23/20 KAD PHASE1 Update Cornelius Kennelly O'Connell 0.60 114.00 claim record in Riskonnect to reflect litigation status and more detailed allegations of the alleged abuse. 07/23/20 KAD PHASE1 Create new claim in Riskonnect for 0.80 152.00 M.T. (Canada) pre-litigation claim. 07/23/20 KAD PHASE1 Create new claim in Riskonnect for 0.80 152.00 M.C. (WI) pre-litigation claim. 07/23/20 KAD PHASE1 Create new claim in Riskonnect for 0.80 152.00 J.H. (NY) pre-litigation claim. 07/23/20 KAD PHASE1 Create new claim in Riskonnect for 0.80 152.00 R.C. (NC) pre-litigation claim. 07/23/20 KAD PHASE1 Analyze lawsuit filed by John Bobeck 0.20 38.00 in preparation of entering same in Riskonnect. 07/23/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by John Bobeck. 07/23/20 KAD PHASE1 Search BSA's internal files for alleged 1.20 228.00 perpetrators named in eight newly filed New York lawsuits. 07/23/20 KAD PHASE1 Search BSA's claim files for a 0.60 114.00 settlement agreement from a historical case (A.S. - PA). 07/24/20 SEM PHASE1 Review email from French Creek 0.20 89.00 Council with information and documents in response to BSA internal file project request and review same. 07/24/20 SEM PHASE1 Email from New Greater Niagara 0.10 44.50 Frontier Council with status report related to search for records related to newly filed New York lawsuits. 07/24/20 SEM PHASE1 Email exchange with BSA and 0.30 133.50 Haynes & Boone regarding the Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 63 of 88
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Date Initials Stage Description Hours Amount potential conflict with Denton's law firm in Georgia and the defense of BSA in the Hartford Insurance adversary action in Delaware. 07/24/20 SEM PHASE1 Begin sending emails to local BSA 3.20 1,424.00 councils with information related to BSA internal file project and requests for records. 07/24/20 SEM PHASE1 Email from Chickasaw Council with 0.20 89.00 information and documents in response to the BSA internal file project and review same. 07/24/20 SEM PHASE1 Email discussion with Glacier's Edge 0.30 133.50 Council regarding logistics of searching for records and information related to the BSA internal file project and review responsive material. 07/24/20 SEM PHASE1 Email from New Jersey defense 0.10 44.50 counsel with report from hearing on co-defendant's motion for a definitive statement in the Luis Lopez case. 07/24/20 SEM PHASE1 Email from C.N.A. Insurance with 0.20 89.00 coverage opinion and tender of defense letters in the Richard Ackerly case in New York and review same. 07/24/20 SEM PHASE1 Email exchange with the Grand 0.20 89.00 Canyon Council regarding request for information pertaining to all pending claims against the council. 07/24/20 SEM PHASE1 Multi-email exchange with the 0.40 178.00 Greater Alabama Council regarding research and findings of information and documents related to the BSA internal file project request and review of the same. 07/24/20 SEM PHASE1 Multiple emails from AIG Insurance 0.10 44.50 with reservation of rights letters for several BSA abuse matters. 07/24/20 SEM PHASE1 Email from Greater Yosemite Council 0.20 89.00 regarding council communications since there is no current Scout Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 64 of 88
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Date Initials Stage Description Hours Amount Executive and forward my concern to BSA with a request for authorization on contact. 07/24/20 SEM PHASE1 Review weekly new claims report to 0.10 44.50 confirm all new claims have been addressed. 07/24/20 SEM PHASE1 Email from the Georgia Carolina 0.20 89.00 Council with information and documents in response to request for same in the BSA internal file project and review same. 07/24/20 SEM PHASE1 Email from the Grand Canyon 0.20 89.00 Council with documents and information in response to BSA internal file project request and review the same. 07/24/20 SEM PHASE1 Email from the Greater Tampa Bay 0.10 44.50 Area Council with information in response to BSA internal file project claims and notice of claim outside their council area. 07/24/20 SEM PHASE1 Research proper council for claim 0.20 89.00 previously sent to Greater Tampa Bay Area Council in the BSA internal file project and redirect same to proper council. 07/24/20 SEM PHASE1 Email from BSA advising to hold off 0.10 44.50 on further communication with the Greater Yosemite Council until we have a new contact there. 07/24/20 SEM PHASE1 Email from Greater Yosemite Council 0.10 44.50 with information related to BSA internal file project request. 07/24/20 SEM PHASE1 Email from BSA agreeing that a 0.10 44.50 response to the perpetrator in the New York Lopez case should come from Haynes and Boone. 07/24/20 KAD PHASE1 Email exchange with Nicole 0.10 19.00 Liberatore regarding notices of second stipulation and agreed order filed in 5 new, New York lawsuits. Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 65 of 88
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Date Initials Stage Description Hours Amount 07/24/20 KAD PHASE1 Email exchanges with Anna Kutz 0.20 38.00 regarding setup of plaintiffs' claim records in Riskonnect and claim numbers. 07/24/20 KAD PHASE1 Analyze Complaint filed by John Cirilo 0.20 38.00 in preparation of entering same in Riskonnect. 07/24/20 KAD PHASE1 Email Robyn Jungers and Anna Kutz 0.10 19.00 regarding entering John Cirilo claim in Riskonnect. 07/24/20 KAD PHASE1 Calculate total number of lawsuits 0.30 57.00 and total number of plaintiffs named in the lawsuits for Anna Kutz. 07/24/20 KAD PHASE1 Update existing John Cirilo OMNI 0.80 152.00 claim in Riskonnect to reflect lawsuit status per Anna Kutz instructions. 07/24/20 KAD PHASE1 Analyze lawsuit filed by Paul Tallerico 0.20 38.00 in preparation of entering same in Riskonnect. 07/24/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by Paul Tallerico. 07/24/20 KAD PHASE1 Analyze lawsuit filed by Peter 0.20 38.00 Barkevich in preparation of entering same in Riskonnect. 07/24/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by Peter Barkevich. 07/24/20 KAD PHASE1 Prepare weekly new claims report. 2.90 551.00 07/24/20 KAD PHASE1 Email Sidley Austin, Alvarez Marsal, 0.10 19.00 BSA and Monica Blacker regarding weekly new abuse claims report. 07/24/20 KAD PHASE1 Email exchange with Anna Kutz and 0.10 19.00 Bruce Griggs regarding Old Republic's request for documents in KY Explorer, Jane Doe and Cote cases. 07/24/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding lawsuit filed by Peter Barkevich and request for information to the Council regarding same. Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 66 of 88
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Date Initials Stage Description Hours Amount 07/27/20 BAG PHASE1 Appear for and attend conference call 0.50 320.00 with Haynes and Boone and Georgia defense counsel to discuss conflicts issues. 07/27/20 SEM PHASE1 Review and respond to a question 0.20 89.00 regarding public school sponsoring of Scouting units posed by Paul Mones. 07/27/20 SEM PHASE1 Email from South Florida Council with 0.20 89.00 information and documents in response to the BSA internal file project request and review the same. 07/27/20 SEM PHASE1 Email exchange with Iroquois Trail 0.20 89.00 Council regarding information related to newly filed Peter Jones case in New York. 07/27/20 SEM PHASE1 Email exchange with Greater Tampa 0.20 89.00 Bay Area Council regarding results of research in response to BSA internal file project request. 07/27/20 SEM PHASE1 Email from Golden Empire Council 0.20 89.00 with contact information for interim Scout Executive and send BSA internal file project request email. 07/27/20 SEM PHASE1 Email from Crater Lake Council with 0.20 89.00 information and records in response to BSA internal file project request and review the same before forwarding to BSA. 07/27/20 SEM PHASE1 Email exchange with Grand Teton 0.20 89.00 Council regarding response to BSA internal file project request. 07/27/20 SEM PHASE1 Telephone call from Great Lakes 0.10 44.50 Field Service Councils regarding additional field service offices with possible claims and request to collect all and send to council for full research into BSA internal file project claims. 07/27/20 SEM PHASE1 Email exchange with Great Trail 0.10 44.50 Council regarding location of historical records and logistics of Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 67 of 88
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Date Initials Stage Description Hours Amount reviewing the same in response to BSA internal file project request. 07/27/20 SEM PHASE1 Email from BSA forwarding 0.20 89.00 correspondence from East Texas Area Council regarding response to BSA internal file project request and respond to the same. 07/27/20 SEM PHASE1 Email from Westchester-Putnam 0.10 44.50 Council advising they have no records related to newly filed lawsuits in New York for Tallerico, Wreden and Snider. 07/27/20 SEM PHASE1 Email from BSA with additional 0.20 89.00 information related to the Stephen Snider lawsuit filed in New York against the Westchester-Putnam Council and forward same to council seeking additional information. 07/27/20 SEM PHASE1 Research all claims related to the 1.00 445.00 Michigan Crossroads Council and all Michigan Field Service Centers and send information related to all claims to the Michigan Crossroads Council per their request. 07/27/20 SEM PHASE1 Email exchange with Connecticut 0.20 89.00 defense counsel regarding Connecticut Yankee Council request for information and reference to Ogletree for response. 07/27/20 SEM PHASE1 Email from Sidley with signed order of 0.30 133.50 dismissal for Cote case in New Hampshire, review and send same to local defense counsel for filing. 07/27/20 SEM PHASE1 Email from Great Rivers Council with 0.20 89.00 information and records in response to BSA internal file project request and review the same. 07/27/20 SEM PHASE1 Email exchange with New Hampshire 0.20 89.00 defense counsel regarding typo in the Court's order allowing dismissal of the Cote case. Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 68 of 88
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Date Initials Stage Description Hours Amount 07/27/20 SEM PHASE1 Emails from Greater Los Angeles 0.20 89.00 Area Council with lawsuits served today and forward same to BSA. 07/27/20 SEM PHASE1 Email exchange with Greater Los 0.20 89.00 Angeles Area Council regarding audit request and response to the same. 07/27/20 SEM PHASE1 Review Manuel Lemos Case served 0.40 178.00 on the Greater Los Angeles Area Council today to add to California lawsuit chart for assigning to local defense counsel. 07/27/20 SEM PHASE1 Email to California defense counsel to 0.20 89.00 assign four new lawsuits filed against the Greater Los Angeles Area Council with background on the same. 07/27/20 SEM PHASE1 Email from New Jersey defense 0.30 133.50 counsel with pleadings filed on behalf of Defendant Bethel Commandment Church of the Living God of New Jersey in the Pedro Lopez case seeking extended stay, review and forward same to BSA. 07/27/20 SEM PHASE1 Continue reviewing spreadsheet of 2.10 934.50 claims not in BSA internal files for continuation of BSA internal file project and to gather information to send to local councils in search of records and information for the same. 07/27/20 SEM PHASE1 Conference call with Haynes and 0.30 133.50 Boone and BSA regarding conflict with Denton's law firm in Georgia and Traveler's Insurance and demand for tender of defense in Lopez case in New Jersey. 07/27/20 SEM PHASE1 Email from New Jersey defense 0.20 89.00 counsel with letter to Court from Defendant Bethel Commandment Church of the Living God of New Jersey in the Priester case advising of extended stay of litigation and review same. Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 69 of 88
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Date Initials Stage Description Hours Amount 07/27/20 SEM PHASE1 Email from the Greater Los Angeles 0.20 89.00 Area Council with update on service of process date for new California lawsuits and forward same to local defense counsel. 07/27/20 SEM PHASE1 Review request for audit for Greater 0.40 178.00 Los Angeles Area Council and collect information for responding to same. 07/27/20 SEM PHASE1 Email Western Los Angeles County 0.20 89.00 Council with BSA internal file project request previously sent to Greater Los Angeles Area Council seeking documents and information related to the same. 07/27/20 SEM PHASE1 Email from Greenwich Council 0.10 44.50 regarding response to BSA internal file project request. 07/27/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding J.H. and J.H. (NY) pre- litigation claims. 07/27/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding R.C. (NC) pre-litigation claim. 07/27/20 KAD PHASE1 Analyze lawsuit filed by J.A. (NY) in 0.20 38.00 preparation of entering same in Riskonnect. 07/27/20 KAD PHASE1 Analyze lawsuit filed by S.A. (NY) in 0.20 38.00 preparation of entering same in Riskonnect. 07/27/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by J.A. (NY). 07/27/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by S.A. (NY). 07/27/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding WA counseling claim. 07/27/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by Thomas Albertini. 07/27/20 KAD PHASE1 Analyze lawsuit filed by Thomas 0.20 38.00 Albertini in preparation of entering Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 70 of 88
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Date Initials Stage Description Hours Amount same in Riskonnect. 07/27/20 KAD PHASE1 Analyze lawsuit filed by Peter Jones 0.20 38.00 in preparation of entering same in Riskonnect. 07/27/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by Peter Jones. 07/27/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding S.A. lawsuit and request for information to the Council regarding same. 07/27/20 KAD PHASE1 Analyze lawsuit filed by Richard 0.20 38.00 Phillips in preparation of entering same in Riskonnect. 07/27/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by Richard Phillips. 07/27/20 KAD PHASE1 Review four summons served upon 0.10 19.00 Greater Los Angeles Area Council and email from Jeff Sulzbach regarding same. 07/27/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by Eugene Sollose. 07/27/20 KAD PHASE1 Analyze lawsuit filed by Eugene 0.20 38.00 Sollose in preparation of entering same in Riskonnect. 07/28/20 BAG PHASE1 Exchange email with Bill Forman at 0.20 128.00 Scheper Kim & Harris regarding new California case assignments and appearances. 07/28/20 BAG PHASE1 Conference call with Anna Kutz and 0.30 192.00 defense counsel regarding BSA conflicts issues. 07/28/20 BAG PHASE1 Internal team meeting to discuss 1.00 640.00 pending claims and items to be completed. 07/28/20 SEM PHASE1 Email discussion with Connecticut 0.30 133.50 defense counsel regarding request for a conference call by Connecticut Yankee Council regarding pending defense matters and guidelines for Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 71 of 88
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Date Initials Stage Description Hours Amount the same. 07/28/20 SEM PHASE1 Email from New Jersey defense 0.10 44.50 counsel with filed Notice of Second Consent Order extension in O'Connell case. 07/28/20 SEM PHASE1 Email exchange with Pennsylvania 0.20 89.00 defense counsel regarding notice of filing lawsuit against BSA and assignment of the same. 07/28/20 SEM PHASE1 Telephone call from Gulf Stream 0.30 133.50 Council to discuss BSA internal file project, research on claims, information discovered and further research issues. 07/28/20 SEM PHASE1 Email from Gulf Coast Council with 0.20 89.00 information and records in response to BSA internal file project request and review the same. 07/28/20 SEM PHASE1 Email to Western Los Angeles 0.30 133.50 Council regarding new John C. Doe lawsuit and request for information related to the same. 07/28/20 SEM PHASE1 Review new lawsuit filed in California 0.80 356.00 for John C. Doe and summarize details of the same for the local council and litigation tracking. 07/28/20 SEM PHASE1 Email to California defense counsel to 0.30 133.50 assign new John C Doe case and authorize filing of Notice of Second Consent Order Extension. 07/28/20 SEM PHASE1 Review BSA internal file for George 0.30 133.50 Stan, perpetrator in the new John C Doe case filed in California. 07/28/20 SEM PHASE1 Complete drafting of response to 0.60 267.00 Greater Los Angeles Area Council auditors regarding request for information related to claims and litigation. 07/28/20 SEM PHASE1 Review new Pennsylvania lawsuit 0.50 222.50 filed only against BSA to obtain Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 72 of 88
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Date Initials Stage Description Hours Amount details for investigation of the claim. 07/28/20 SEM PHASE1 Draft email to send to Pennsylvania 0.20 89.00 BSA councils seeking information related to Powers case filed there without identification of Council. 07/28/20 SEM PHASE1 Telephone call from Connecticut 0.20 89.00 Yankee Council president to discuss council claims, coverage matters and bankruptcy issues. 07/28/20 SEM PHASE1 Email to Connecticut Yankee Council 0.20 89.00 attorney with contact details for Haynes and Boone and Sidley Austin for inquiry regarding coverage and bankruptcy issues. 07/28/20 SEM PHASE1 Telephone call with Hudson Valley 0.20 89.00 Council regarding preliminary results and impediments to search for records related to BSA internal file project and efforts to do so. 07/28/20 SEM PHASE1 Communicate with Allegheny 0.30 133.50 Highlands Council regarding new lawsuit filed for Brian Eller and communications with new media. 07/28/20 SEM PHASE1 Research background of Plaintiff Dr. 0.40 178.00 Richard Powers DDS in Pennsylvania to collect information about his new lawsuit filed there and send information request to appropriate council. 07/28/20 SEM PHASE1 Review new lawsuit filed in New York 0.30 133.50 for Brian Eller and summarize information for the lawsuit tracking sheet. 07/28/20 SEM PHASE1 Review six (6) additional new lawsuits 0.30 133.50 filed in New York and summarize same for local council requests for information. 07/28/20 SEM PHASE1 Conference call with Haynes and 0.20 89.00 Boone and Georgia defense counsel regarding potential conflict with Traveler's insurance representation Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 73 of 88
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Date Initials Stage Description Hours Amount by Denton's. 07/28/20 SEM PHASE1 Conference call with BSA to advise of 0.10 44.50 resolution of Denton's conflict in the Traveler's matter. 07/28/20 SEM PHASE1 Email exchange with Melick & Porter 0.30 133.50 regarding communication with Plaintiff's counsel in the Thomas Ellison case in New York regarding the injunction notice filing and forward to Wiggin & Dana to follow-up with the same. 07/28/20 SEM PHASE1 Email from Crossroads of America 0.20 89.00 Council with information in response to BSA internal file project and review same. 07/28/20 SEM PHASE1 Email exchange with California 0.20 89.00 defense counsel seeking additional documents received by Greater Los Angeles Area Council and status conferences set by the court. 07/28/20 KAD PHASE1 Review notice of new lawsuit filed in 0.10 19.00 Philadelphia. 07/28/20 KAD PHASE1 Review email from Joseph Morgese 0.10 19.00 regarding notice of second stipulation and agreed order filed in O'Connell lawsuit. 07/28/20 KAD PHASE1 Review email from Anna Kutz 0.10 19.00 regarding new lawsuit filed in California by John C Doe. 07/28/20 KAD PHASE1 Review email from Joseph Odea 0.10 19.00 regarding new lawsuit filed in Philadelphia Court. 07/28/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding lawsuit filed by Richard Phillips and request for information to the Council regarding same. 07/28/20 KAD PHASE1 Update Manuel Lemos claim record 0.10 19.00 in Riskonnect to reflect assignment of defense counsel and completion of service upon the Local Council. Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 74 of 88
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Date Initials Stage Description Hours Amount 07/28/20 KAD PHASE1 Communicate with Robyn Jungers 0.10 19.00 and Anna Kutz via Chatter regarding assignment of defense counsel for Manuel Lemos claim. 07/28/20 KAD PHASE1 Communicate with Robyn Jungers 0.10 19.00 and Anna Kutz via Chatter regarding assignment of defense counsel for Charles Wright claim. 07/28/20 KAD PHASE1 Update Charles Wright claim record 0.10 19.00 in Riskonnect to reflect assignment of defense counsel and completion of service upon the Local Council. 07/28/20 KAD PHASE1 Update Paul Turley claim record in 0.10 19.00 Riskonnect to reflect assignment of defense counsel and completion of service upon the Local Council. 07/28/20 KAD PHASE1 Communicate with Robyn Jungers 0.10 19.00 and Anna Kutz via Chatter regarding assignment of defense counsel for Paul Turley claim. 07/28/20 KAD PHASE1 Communicate with Robyn Jungers 0.10 19.00 and Anna Kutz via Chatter regarding assignment of defense counsel for Marcus Nelson claim. 07/28/20 KAD PHASE1 Update Marcus Nelson claim record 0.10 19.00 in Riskonnect to reflect assignment of defense counsel and completion of service upon the Local Council. 07/28/20 KAD PHASE1 Prepare Greater Los Angeles Area 1.80 342.00 Council claims report to assist attorney with responding to audit letter. 07/28/20 KAD PHASE1 Search BSA's internal files for alleged 0.20 38.00 perpetrator named in John C Doe lawsuit. 07/28/20 KAD PHASE1 Search BSA's internal files for alleged 0.20 38.00 perpetrator named in Richard Powers lawsuit. 07/28/20 KAD PHASE1 Work on reserves report for client. 3.90 741.00 07/28/20 KAD PHASE1 Review email from Vanessa Savoy 0.10 19.00 Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 75 of 88
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Date Initials Stage Description Hours Amount regarding changes to Riskonnect and month-end reporting, forward same to Katie Murray. 07/29/20 SEM PHASE1 Email exchange with French Creek 0.30 133.50 Council regarding information and documents discovered in relation to the newly filed Pennsylvania lawsuit for Brian Eller and review the same. 07/29/20 SEM PHASE1 Review current status of BSA internal 0.40 178.00 file project, potential for BSA internal file production in bankruptcy, and other ongoing BSA projects with Kelci Davis. 07/29/20 SEM PHASE1 Review the latest news media 0.30 133.50 regarding claims of "Suspicious Asset Transfers" by local councils, claims allowed despite statute of limitations, and additional lawsuits being filed in New York prior to the close of the extended grace period. 07/29/20 SEM PHASE1 Review document from BSA with 0.20 89.00 proposal for ongoing programming. 07/29/20 SEM PHASE1 Review new lawsuits filed in New 1.20 534.00 York and summarize same for sending to local councils. 07/29/20 SEM PHASE1 Request BSA internal files for alleged 0.10 44.50 perpetrators in the new lawsuits filed in New York for review prior to sending information to the local councils. 07/29/20 SEM PHASE1 Email New York defense counsel 0.40 178.00 firms to assign newly filed lawsuits there. 07/29/20 SEM PHASE1 Email exchange with New York 0.20 89.00 defense counsel regarding the appropriateness of filing the Notice of Second Extension of the Consent Order on behalf of the local council where BSA National is not a party. 07/29/20 SEM PHASE1 Email exchange with Susquehanna 0.30 133.50 Council in Pennsylvania regarding Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 76 of 88
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Date Initials Stage Description Hours Amount information found or not found in search for material related to new Powers lawsuit and review the same. 07/29/20 SEM PHASE1 Telephone call from Michigan 0.10 44.50 Crossroads Council to discuss information discovered as a result of BSA internal file project request. 07/29/20 SEM PHASE1 Email to Juniata Valley Council with 0.30 133.50 background of Powers case filed in Pennsylvania and request for information related to the same. 07/29/20 SEM PHASE1 Email from Great Lakes Field Service 0.20 89.00 Councils with information and documents in response to BSA internal file project request and review the same. 07/29/20 SEM PHASE1 Draft emails to New York local 0.50 222.50 councils with new lawsuits filed there with summaries of the same and requests for information. 07/29/20 SEM PHASE1 Email discussion with California 0.40 178.00 defense counsel regarding service and defense of local councils in the Marcus Nelson case and research related to the same. 07/29/20 SEM PHASE1 Email from Juniata Valley Council in 0.10 44.50 response to request for information pertaining to new Powers lawsuit filed in Pennsylvania. 07/29/20 SEM PHASE1 Review issue of new Plaintiff in New 0.20 89.00 York, Redacted , being the same plaintiff as KS Doe 15 and need to have local defense counsel follow-up with Plaintiff's counsel. 07/29/20 SEM PHASE1 Review New York lawsuit for Redacted 0.50 222.50 Redacted, summarize same for case tracking and compare to KS Doe 15 case. 07/29/20 SEM PHASE1 Email exchange with Greater Niagara 0.30 133.50 Frontier Council in New York and local defense counsel regarding new Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 77 of 88
Page 76 08/17/20 Bill No. 90257759 047657.000013-BAG
Date Initials Stage Description Hours Amount Redacted lawsuit and need to discuss same with Plaintiff's counsel regarding KS Doe 15 and conflict. 07/29/20 SEM PHASE1 Email exchange with California 0.30 133.50 defense counsel regarding the Marcus Nelson lawsuit, scheduled case management conference, modified Notice to file in case and review same. 07/29/20 SEM PHASE1 Review 64 claims pending valuations 1.50 667.50 and provide same pursuant to the BSA matrix. 07/29/20 SEM PHASE1 Extended email discussion with 0.40 178.00 California defense counsel regarding strategy for filings Notices of Consent Orders, procedure and cost for the same. 07/29/20 KAD PHASE1 Review email from Anna Kutz 0.10 19.00 regarding new lawsuit filed by Brian Eller in New York. 07/29/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding case documents from historical claims. 07/29/20 KAD PHASE1 Review news article regarding lawsuit 0.10 19.00 that could allow sex abuse victims to file claims even if their states' limitations expired. 07/30/20 BAG PHASE1 Review email exchanges regarding 0.10 64.00 entry of appearances in new California cases. 07/30/20 BAG PHASE1 Begin review and analysis of 30 new 2.50 1,600.00 Complaints/cases filed in New York on July 30. 07/30/20 SEM PHASE1 Email exchange with New York 0.30 133.50 defense counsel Melick & Porter regarding the new Redacted lawsuit and issue of multiple simultaneous lawsuits pending by this plaintiff and forward information regarding same to New York defense counsel Wiggin & Dana to inquire Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 78 of 88
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Date Initials Stage Description Hours Amount with plaintiff regarding the same. 07/30/20 SEM PHASE1 Email exchange with Allegheny 0.20 89.00 Highlands Council regarding two new lawsuits served on the council. 07/30/20 SEM PHASE1 Email from Theodore Roosevelt 0.10 44.50 Council regarding results of review for records in the new Thomas Albertini lawsuit. 07/30/20 SEM PHASE1 Multiple emails from Washington 0.30 133.50 State defense counsel with Entries of Appearance for attorney for co- defendant Bethel Grange in all four Plaintiff cases there and respond regarding the same. 07/30/20 SEM PHASE1 Review news stories regarding local 0.20 89.00 councils receiving government funds for COVID-19 relief being an abomination of justice and seeking the death of the BSA. 07/30/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 newly filed and served John Doe 34 C.P. and AB 417 Doe lawsuits filed in New York. 07/30/20 SEM PHASE1 Email exchange with BSA regarding 0.30 133.50 additional service of Turley, Lemons, Nelson and Wright lawsuits on the Orange County Council and effect on local defense counsel response and review said filing papers. 07/30/20 SEM PHASE1 Email to California defense counsel 0.20 89.00 with newly served summons and complaints on the Orange County Council in the Lemos, Wright, Turley and Nelson cases. 07/30/20 SEM PHASE1 Email from New Jersey defense 0.20 89.00 counsel with su sponte order of the court dismissing the Johnson v. BSA case and review same. 07/30/20 SEM PHASE1 Email to Sidley regarding update to 0.10 44.50 consent order schedules and need for time to do so based on the number of Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 79 of 88
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Date Initials Stage Description Hours Amount new claims received lately. 07/30/20 SEM PHASE1 Email exchange with California 0.20 89.00 defense counsel regarding a plan to accept service of new lawsuits and have Plaintiff's advise the court of the stay to try and avoid the excessive filing fees. 07/30/20 SEM PHASE1 Email from Cradle of Liberty Council 0.20 89.00 in Pennsylvania regarding inability to locate records related to the Redacted claim and forward same to BSA. 07/30/20 SEM PHASE1 Review BSA internal file for John 0.50 222.50 Lancaster, alleged perpetrator in new lawsuit filed in New York, summarize same and send update to Westchester-Putnam Council. 07/30/20 SEM PHASE1 Email from Cradle of Liberty Council 0.20 89.00 in Pennsylvania with response to BSA internal file project inquiry and review information and documents from the same. 07/30/20 SEM PHASE1 Email from the Golden Spread 0.20 89.00 Council with response to BSA internal file project request and review information and documents provided. 07/30/20 SEM PHASE1 Email exchange with Seneca 0.20 89.00 Waterways Council regarding request to obtain Plaintiff's true identity. 07/30/20 SEM PHASE1 Review information of 30 new BSA 0.10 44.50 abuse lawsuits filed this week in New York. 07/30/20 SEM PHASE1 Review emails and attached 0.20 89.00 correspondence from General Star Indemnity Company regarding the request for documents and information related to multiple OMNI and other claims and litigation and position on the same. 07/30/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 letter of representation letter for Redacted in New Jersey and Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 80 of 88
Page 79 08/17/20 Bill No. 90257759 047657.000013-BAG
Date Initials Stage Description Hours Amount review the same. 07/30/20 SEM PHASE1 Email to counsel for Redacted 0.40 178.00 related to her New Jersey abuse claim with Proof of Claim Notice and Form. 07/30/20 SEM PHASE1 Email discussion with Western Los 0.30 133.50 Angeles County Council regarding research on information related to AIS claim for BSA internal file project. 07/30/20 SEM PHASE1 Email from Western Los Angeles 0.10 44.50 County Council regarding information related to new John C Doe lawsuit. 07/30/20 SEM PHASE1 Email discussion with the Golden 0.30 133.50 Spread Council regarding information and records related to BSA internal file project request. 07/30/20 SEM PHASE1 Review news story related to new 0.20 89.00 abuse lawsuit filed against the Allegheny Highlands Council as advised about yesterday by the Council and send same to BSA. 07/30/20 SEM PHASE1 Draft email to Verdugo Hills Council 0.40 178.00 in search of records related to AIS- 0044 claim with background on the same. 07/30/20 SEM PHASE1 Email to BSA regarding additional 0.20 89.00 new lawsuits being filed in New York and background on the reasoning behind the same. 07/30/20 SEM PHASE1 Review and analyze news sources 0.40 178.00 from New York regarding the governor's signing of the extension of the Child Victim's Act. 07/30/20 SEM PHASE1 Begin review of 30 additional new 1.00 445.00 lawsuits filed in New York this week and collect data for litigation tracking chart and to send local councils with requests for information. 07/30/20 SEM PHASE1 Begin sending emails to local New 0.50 222.50 York councils with newly filed lawsuits and requests for information related Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 81 of 88
Page 80 08/17/20 Bill No. 90257759 047657.000013-BAG
Date Initials Stage Description Hours Amount to the same. 07/30/20 SEM PHASE1 Emails to New York defense counsels 0.30 133.50 to assign newly filed lawsuits and request for actual Plaintiff names. 07/30/20 SEM PHASE1 Request BSA internal files for 0.10 44.50 identified perpetrators in newly filed New York lawsuits for review. 07/30/20 KAD PHASE1 Review email from Anna Kutz 0.10 19.00 regarding two new lawsuits filed in New York. 07/30/20 KAD PHASE1 Review email from Anna Kutz 0.10 19.00 regarding California lawsuits received at national from Orange County Scout Shop. 07/30/20 KAD PHASE1 Search BSA's internal files for alleged 0.70 133.00 perpetrators named in newly filed New York lawsuits. 07/30/20 KAD PHASE1 Email exchange with Nicole 0.10 19.00 Liberatore regarding notices of second stipulation and agreed order filed in 5 new, New York lawsuits. 07/30/20 KAD PHASE1 Email exchange with William Curtain 0.10 19.00 regarding Schedule 1 Chart of Pending Abuse Actions. 07/30/20 KAD PHASE1 Email exchange with Anna Kutz 0.10 19.00 regarding new pre-litigation claim (K.C.) to enter into Riskonnect. 07/30/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by Anthony Sambula. 07/30/20 KAD PHASE1 Analyze lawsuit filed by Anthony 0.20 38.00 Sambula in preparation of entering same in Riskonnect. 07/30/20 KAD PHASE1 Analyze lawsuit filed by LG 63 Doe in 0.20 38.00 preparation of entering same in Riskonnect. 07/30/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by LG 63 Doe. 07/30/20 KAD PHASE1 Analyze lawsuit filed by LG 81 Doe in 0.20 38.00 Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 82 of 88
Page 81 08/17/20 Bill No. 90257759 047657.000013-BAG
Date Initials Stage Description Hours Amount preparation of entering same in Riskonnect. 07/30/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by LG 81 Doe. 07/30/20 KAD PHASE1 Review court order dismissing BSA 0.10 19.00 from the lawsuit filed by Edwin Johnson. 07/31/20 BAG PHASE1 Review email from defense counsel 0.20 128.00 in J.C. v BSA (VA) regarding Scout Master's request for indemnification and exchange email correspondence with Anna Kutz regarding same. 07/31/20 SEM PHASE1 Email from Greater New York 0.10 44.50 Councils advising no information was recovered regarding the John Cirilo lawsuit. 07/31/20 SEM PHASE1 Email from Gulf Stream Council with 0.20 89.00 information and documents in response to the BSA internal file project request and review the same. 07/31/20 SEM PHASE1 Review information and documents 0.20 89.00 received from the Heart of America Council in response to the BSA internal file request and review the same. 07/31/20 SEM PHASE1 Review Weekly Claims Report to see 0.10 44.50 additional new claims not already processed. 07/31/20 SEM PHASE1 Email exchange with Sidley regarding 0.20 89.00 number of new claims being filed in New York and difficulty in tracking same for Consent Order Schedule purposes. 07/31/20 SEM PHASE1 Email discussion with Verdugo Hills 0.30 133.50 Council regarding research and information related to the AIS - 0044 claim. 07/31/20 SEM PHASE1 Review information indicating that 0.10 44.50 Plaintiff's counsel Jeff Anderson filed over 60 new lawsuits in New York this Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 83 of 88
Page 82 08/17/20 Bill No. 90257759 047657.000013-BAG
Date Initials Stage Description Hours Amount week. 07/31/20 SEM PHASE1 Email from Andrew Jackson Council 0.20 89.00 with information and documents in response to BSA internal file request and review same. 07/31/20 SEM PHASE1 Email exchange with Virginia defense 0.20 89.00 counsel regarding individual defendant Scoutmaster in the J.C. case requesting a defense and indemnity. 07/31/20 SEM PHASE1 Email discussion with BSA regarding 0.30 133.50 individual defendant Scoutmaster in the J.C. case requesting a defense and indemnity and need for a summary of the case to provide Old Republic Insurance with the request for the same. 07/31/20 SEM PHASE1 Email exchange with BSA providing a 0.20 89.00 report of the conflict issue in Georgia and resolution of the same. 07/31/20 SEM PHASE1 Email from New Hampshire defense 0.20 89.00 counsel with Cote final dismissal and review the same. 07/31/20 KAD PHASE1 Email exchange with William Curtain 0.10 19.00 regarding Schedule 1 Chart of Pending Abuse Actions. 07/31/20 KAD PHASE1 Search BSA's internal files for alleged 0.20 38.00 perpetrator named in the John Doe 34 C.P. lawsuit. 07/31/20 KAD PHASE1 Review email from Vanessa Savoy 0.10 19.00 regarding changes to Riskonnect and month-end reporting, forward same to Katie Murray. 07/31/20 KAD PHASE1 Email exchange with Nicole 0.10 19.00 Liberatore regarding notices of second stipulation and agreed order filed in 3 new, New York lawsuits. 07/31/20 KAD PHASE1 Email Sidley Austin, Alvarez Marsal, 0.10 19.00 BSA and Monica Blacker regarding weekly new abuse claims report. Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 84 of 88
Page 83 08/17/20 Bill No. 90257759 047657.000013-BAG
Date Initials Stage Description Hours Amount 07/31/20 KAD PHASE1 Prepare weekly new claims report. 6.00 1,140.00 07/31/20 KAD PHASE1 Begin revising Schedule 1 Chart of 1.00 190.00 Pending Abuse Actions.
Total Services: 338.00 124,292.50
Timekeeper Summary Timekeeper Title Rate Hours Amount Bruce A. Griggs Shareholder 640.00 44.80 28,672.00 Sean E. Manning Of Counsel 445.00 157.10 69,909.50 Kelci A. Davis Paralegal 190.00 132.40 25,156.00 Katie J. Murray Other 150.00 3.70 555.00 Expenses Description Amount VENDOR: Epiq eDiscovery Solutions, Inc.- AZ INVOICE#: 90457254 DATE: 7/8/2020 81.19 Professional Fees - Epiq eDiscovery Solutions, Inc.- AZ - E-discovery storage - on 06/01/20 Total Expenses 81.19
TOTAL FEES $124,292.50 TOTAL EXPENSES $81.19 TOTAL THIS BILL $124,373.69 Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 85 of 88
FILE COPY ONLY – BILL OGLETREE, DEAKINS, NASH, SUBMITTED ELECTRONICALLY SMOAK & STEWART, P.C. DO NOT SUBMIT TO CLIENT Attorneys at Law UNLESS EXPRESSLY Administrative Office REQUESTED BY CLIENT 50 International Drive Patewood IV, Suite 200 Greenville, SC 29615 August 17, 2020 Telephone: (864) 241-1900 Facsimile: (864) 241-1908 www.ogletreedeakins.com
Elizabeth Ramirez-Washka Boy Scouts of America, The - DIP 1325 West Walnut Hill Lane P.O. Box 152079 Irving, TX 75015-2079
PERSONAL AND CONFIDENTIAL Bill # 90261042 Client.Matter # 083331.000000
Re: Boy Scouts of America, The - General Advice
For professional services rendered through July 31, 2020, in connection with the above-referenced matter as outlined on the attached detailed billing sheets:
Fees ...... $4,429.35 Expenses...... $0.00
Total Due This Bill...... $4,429.35
Atlanta ▪ Austin ▪ Berlin (Germany) ▪ Birmingham ▪ Boston ▪ Charleston ▪ Charlotte ▪ Chicago ▪ Cleveland ▪ Columbia ▪ Dallas ▪ Denver ▪ Detroit Metro ▪ Greenville ▪ Houston Indianapolis ▪ Jackson ▪ Kansas City ▪ Las Vegas ▪ London (England) ▪ Los Angeles ▪ Memphis ▪ Mexico City (Mexico) ▪ Miami ▪ Milwaukee ▪ Minneapolis ▪ Montréal (Canada) ▪ Morristown Nashville ▪ New Orleans ▪ New York City ▪ Oklahoma City ▪ Orange County ▪ Paris (France) ▪ Philadelphia ▪ Phoenix ▪ Pittsburgh ▪ Portland, ME ▪ Portland, OR ▪ Raleigh Richmond ▪ St. Louis ▪ St. Thomas ▪ Sacramento ▪ San Antonio ▪ San Diego ▪ San Francisco ▪ Seattle ▪ Stamford ▪ Tampa ▪ Toronto (Canada) ▪ Torrance ▪ Tucson ▪ Washington Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 86 of 88
Page 2 08/17/20 Bill No. 90261042 083331.000000-RWC
Elizabeth Ramirez-Washka Boy Scouts of America, The - DIP 1325 West Walnut Hill Lane P.O. Box 152079 Irving, TX 75015-2079
Re: Boy Scouts of America, The - General Advice
For professional services rendered through July 31, 2020
Date Initials Stage Description Hours Amount 07/06/20 GSM PHASE1 Analyze various documents regarding 1.30 538.20 internal complaint about certain social media posts by an employee, and exchange multiple detailed emails with Elizabeth Washka regarding same. 07/14/20 JRS PHASE1 Analyze, edit, and revise separation 0.30 117.45 agreement pursuant to emails from Elizabeth Washka. 07/14/20 MAC PHASE1 Analyze client spreadsheet, format 0.80 180.00 received data, conduct RIF statistical analysis on decisional unit(s) and summarize statistical findings. 07/15/20 GWE PHASE1 Review statistical analysis and 0.30 144.45 summarize it in email to Elizabeth Washka, Lisa Young and Ken Ceaser. 07/15/20 GWE PHASE1 Telephone conference with Elizabeth 0.40 192.60 Washka, Lisa Young, and Ken Ceaser concerning statistical analysis of RIF. 07/16/20 RWC PHASE1 Review email string received from 0.10 64.80 Joe Zirkman and respond to same. 07/16/20 RWC PHASE1 Prepare template waiver and 0.60 388.80 assumption of the risk document and send to Joe Zirkman. 07/16/20 GSM PHASE1 Draft status report of all pending 0.30 124.20 matters. 07/16/20 JRS PHASE1 Edit and revise clawback language 0.40 156.60 for severance agreement and send to Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 87 of 88
Page 3 08/17/20 Bill No. 90261042 083331.000000-RWC
Date Initials Stage Description Hours Amount Elizabeth Washka. 07/20/20 GAS PHASE1 Teleconference with Adam Boland 0.30 124.20 concerning background check form questions. 07/20/20 GSM PHASE1 Revise monthly status report 0.40 165.60 regarding all pending matters. 07/27/20 CEM PHASE1 Review PTO issues involving 0.20 85.50 severance from Elizabeth Washka. 07/27/20 CEM PHASE1 Review PTO chart and draft language 0.30 128.25 to amend severance agreements and email to Ken Caesar. 07/27/20 GSM PHASE1 Analyze separation agreement and 1.10 455.40 related emails as requested by Bill Davis, and exchange emails with Mr. Davis regarding same. 07/28/20 GSM PHASE1 Analyze inquiry regarding wage 0.60 248.40 garnishments in severance pay and coordinate response to Bill Davis regarding same. 07/28/20 JAT PHASE1 Analyze wage withholding issues 0.40 147.60 from employee severance agreement. 07/29/20 CEM PHASE1 Review Texas wage and hour law 0.40 171.00 and draft email to Elizabeth Washka regarding whether BSA can withhold severance from employees that refuse to return company issued laptops. 07/29/20 CEM PHASE1 Draft sample language to include in 0.20 85.50 severance agreement. 07/30/20 GSM PHASE1 Draft detailed and complex transition 2.20 910.80 and supplemental severance agreement for employee who would take paid leave before termination date, and exchange several detailed emails with Elizabeth Washka regarding same and related strategy.
Total Services: 10.60 4,429.35 Case 20-10343-LSS Doc 1137-2 Filed 08/21/20 Page 88 of 88
Page 4 08/17/20 Bill No. 90261042 083331.000000-RWC
Timekeeper Summary Timekeeper Title Rate Hours Amount James R. Silvers Shareholder 391.50 0.70 274.05 J. Allen Thomas Shareholder 369.00 0.40 147.60 Gavin S. Martinson Shareholder 414.00 5.90 2,442.60 Charles E. McDonald, III Shareholder 427.50 1.10 470.25 Ron Chapman, Jr. Shareholder 648.00 0.70 453.60 Gretchen W. Ewalt Of Counsel 481.50 0.70 337.05 Gustavo A. Suarez Of Counsel 414.00 0.30 124.20 Malia A. Crane Other 225.00 0.80 180.00
TOTAL FEES $4,429.35 TOTAL EXPENSES $0.00 TOTAL THIS BILL $4,429.35 Case 20-10343-LSS Doc 1137-3 Filed 08/21/20 Page 1 of 5
Exhibit B
Phase 2 Fees and Expense Itemization
Case 20-10343-LSS Doc 1137-3 Filed 08/21/20 Page 2 of 5
FILE COPY ONLY – BILL OGLETREE, DEAKINS, NASH, SUBMITTED ELECTRONICALLY SMOAK & STEWART, P.C. DO NOT SUBMIT TO CLIENT Attorneys at Law UNLESS EXPRESSLY Administrative Office REQUESTED BY CLIENT 50 International Drive Patewood IV, Suite 200 Greenville, SC 29615 August 17, 2020 Telephone: (864) 241-1900 Facsimile: (864) 241-1908 www.ogletreedeakins.com
Robyn Jungers The Boy Scouts of America Legal Department 1325 West Walnut Hill Lane P.O. Box 152079 Irving, TX 75015-2049
PERSONAL AND CONFIDENTIAL Bill # 90257758 Client.Matter # 047657.000013
Re: BSA General Defense - Bankruptcy (Billiable) Phase 2
For professional services rendered through July 31, 2020, in connection with the above-referenced matter as outlined on the attached detailed billing sheets:
Fees ...... $8,209.00 Expenses...... $0.00
Total Due This Bill...... $8,209.00
Atlanta ▪ Austin ▪ Berlin (Germany) ▪ Birmingham ▪ Boston ▪ Charleston ▪ Charlotte ▪ Chicago ▪ Cleveland ▪ Columbia ▪ Dallas ▪ Denver ▪ Detroit Metro ▪ Greenville ▪ Houston Indianapolis ▪ Jackson ▪ Kansas City ▪ Las Vegas ▪ London (England) ▪ Los Angeles ▪ Memphis ▪ Mexico City (Mexico) ▪ Miami ▪ Milwaukee ▪ Minneapolis ▪ Montréal (Canada) ▪ Morristown Nashville ▪ New Orleans ▪ New York City ▪ Oklahoma City ▪ Orange County ▪ Paris (France) ▪ Philadelphia ▪ Phoenix ▪ Pittsburgh ▪ Portland, ME ▪ Portland, OR ▪ Raleigh Richmond ▪ St. Louis ▪ St. Thomas ▪ Sacramento ▪ San Antonio ▪ San Diego ▪ San Francisco ▪ Seattle ▪ Stamford ▪ Tampa ▪ Toronto (Canada) ▪ Torrance ▪ Tucson ▪ Washington Case 20-10343-LSS Doc 1137-3 Filed 08/21/20 Page 3 of 5
Page 2 08/17/20 Bill No. 90257758 047657.000013-BAG
Robyn Jungers The Boy Scouts of America Legal Department 1325 West Walnut Hill Lane P.O. Box 152079 Irving, TX 75015-2049
Re: BSA General Defense - Bankruptcy (Billiable) Phase 2
For professional services rendered through July 31, 2020
Date Initials Stage Description Hours Amount 07/02/20 BAG PHASE2 Review revised interim fee application 0.50 320.00 and information to be provided to the US Trustee and exchange email with Eric Moats regarding same. 07/06/20 BAG PHASE2 Review and respond to email from 0.10 64.00 Morris Nichols legal assistant regarding Third Interim Fee Application. 07/07/20 BAG PHASE2 Review Initial Omnibus Order and 0.20 128.00 internal conferences with Kelci Davis regarding same. 07/07/20 BAG PHASE2 Work on redaction of privileged 2.00 1,280.00 information from Pre-bills in preparation for submission of Monthly Fee Application. 07/07/20 KAD PHASE2 Review email from Desiree Vale 0.10 19.00 regarding receipt of any informal comment regarding Ogletree's Third Fee Application. 07/07/20 KAD PHASE2 Review BSA's First Onnibus Fee 0.30 57.00 Order and email from Desiree Vale regarding same. 07/07/20 KAD PHASE2 Review and confirm numbers in 0.40 76.00 Omnibus Fee Order are correct. 07/08/20 BAG PHASE2 Review multiple emails from Morris 0.20 128.00 Nichols regarding Omnibus Order and fee information and attention to same. 07/10/20 KAD PHASE2 Analyze June's billing entries and 4.10 779.00 Case 20-10343-LSS Doc 1137-3 Filed 08/21/20 Page 4 of 5
Page 3 08/17/20 Bill No. 90257758 047657.000013-BAG
Date Initials Stage Description Hours Amount information for inclusion in the monthly fee application for July. 07/13/20 BAG PHASE2 Work on preparation of monthly fee 1.50 960.00 application and all required invoices. 07/13/20 KAD PHASE2 Analyze Epic invoice and submit 0.10 19.00 same for processing and payment. 07/15/20 BAG PHASE2 Continue redaction of privileged 2.50 1,600.00 information for monthly fee application and work on application. 07/16/20 BAG PHASE2 Review email from Anna Kutz 0.20 128.00 regarding inclusion of Washington defense counsel on OCP designations and attention to same. 07/16/20 KAD PHASE2 Calculate the total amount requested 0.20 38.00 in Ogletree's fee applications for the last three months to assist attorney with year-end expense forecast. 07/20/20 BAG PHASE2 Complete review of June invoices for 1.00 640.00 redaction and privileged information. 07/21/20 BAG PHASE2 Complete work on fourth monthly fee 0.50 320.00 application. 07/21/20 KAD PHASE2 Prepare initial draft of Ogletree's 2.90 551.00 Fourth Monthly Fee Application. 07/21/20 KAD PHASE2 Review/analyze billing entries and 3.80 722.00 invoices for inclusion in Ogletree's Fourth Monthly Fee Application and work on required redaction for same. 07/21/20 KAD PHASE2 Review email from Eric Moats 0.10 19.00 regarding Ogletree's Fourth Monthly Fee Application. 07/21/20 KAD PHASE2 Revise Ogletree's Fourth Monthly 0.30 57.00 Fee Application based on comments from Eric Moats. 07/22/20 KAD PHASE2 Email exchange with Eric Moats 0.10 19.00 regarding phase 1 and 2 bills. 07/22/20 KAD PHASE2 Email exchange with Eric Moats 0.10 19.00 regarding revisions to Ogletree's Fourth Monthly Fee Application. Case 20-10343-LSS Doc 1137-3 Filed 08/21/20 Page 5 of 5
Page 4 08/17/20 Bill No. 90257758 047657.000013-BAG
Date Initials Stage Description Hours Amount 07/30/20 KAD PHASE2 Compile billing information on 22 New 1.30 247.00 York lawsuits assigned to Melick & Porter. 07/30/20 KAD PHASE2 Email exchange with Lauren Roche 0.10 19.00 regarding instructions for billing on 22 new lawsuits assigned to Melick and Porter.
Total Services: 22.60 8,209.00
Timekeeper Summary Timekeeper Title Rate Hours Amount Bruce A. Griggs Shareholder 640.00 8.70 5,568.00 Kelci A. Davis Paralegal 190.00 13.90 2,641.00
TOTAL FEES $8,209.00 TOTAL EXPENSES $0.00 TOTAL THIS BILL $8,209.00 Case 20-10343-LSS Doc 1137-4 Filed 08/21/20 Page 1 of 1
Exhibit C
Expense Summary
Category Amount Legal Support Services $81.19 TOTAL: $81.19
43899678.2