Case 20-10343-LSS Doc 4262 Filed 05/17/21 Page 1 of 11
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: June 1, 2021 at 4:00 p.m. (ET)
SUMMARY COVER SHEET OF THIRTEENTH MONTHLY APPLICATION OF OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C. FOR ALLOWANCE OF COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR THE PERIOD FROM MARCH 1, 2021 TO AND INCLUDING MARCH 31, 2021
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: March 1, 2021 – March 31, 2021
Amount of Compensation Requested: $116,402.80 (80% of $145,503.50) 2
Amount of Compensation Requested from Insurers: $6,641.50
Amount of Expense Reimbursement Requested: $81.19
Amount of Expense Reimbursement Requested from $2,652.68 Insurers:
Amount of Expense Reimbursement Requested for $11.24 Immigration Matters:
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 Ogletree Deakins’ work with respect to immigration matters is billed as a flat fee, and, therefore, no hours are asso- ciated with the work performed. Furthermore, the compensation requested for immigration matters includes work performed prior to the Fee Period, but that Ogletree Deakins has yet to be compensated for.
Case 20-10343-LSS Doc 4262 Filed 05/17/21 Page 2 of 11
PRIOR MONTHLY APPLICATIONS FILED
Requested Approved Outstanding Date Filed; Period Covered Fees Expenses Fees Expenses Fees Expenses Docket No. 4/29/2020; D.I. 512 February 18, 2020 – $393,030.80 $1,923.42 $387,179.80 $1,923.42 $ - $ - March 31, 2020
5/28/2020;D.I. 717 April 1, 2020 – $146,042.10 $128.96 $140,191.10 $128.96 $ - $ - April 30, 2020
6/18/2020; D.I. 867 May 1, – May 31, $128,646.50 $627.81 $122,795.50 $627.81 $ - $ - 2020
7/22/2020; D.I. 1037 June 1, 2020 – June $133,225.40 $81.19 $127,374.40 $81.91 $ - $ - 30, 2020
8/21/2020; D.I. 1137 July 1, 2020 – July $136,930.85 $81.19 $131,079.85 $81.91 $ - $ - 31, 2020
10/1/2020; D.I. 1392 August 1, 2020 – $129,960.70 $100.31 $127,488.52 $100.31 $25,922.14 $ - August 31, 2020
11/3/2020; D.I. 1625 September 1, 2020 $109,548.70 $81.19 $107,071.54 $81.91 $21909.74 $ - – September 30, 2020 12/3/2020; D.I. 1781 October 1, 2020 – $135,773.15 $81.19 $133,295.99 $81.91 $27,154.63 $ - October 31, 2020
1/14/2021; D.I. 1947 November 1, 2020 – $148,984.60 $28,415.43 $119,187.68 $28,415.43 $29,796.92 $ - November 30, 2020
2/17/2021; D.I. 2236 December 1, 2020 – $163,709.55 $81.19 $130,967.64 $81.19 $32,741.91 $ - December 31, 2020
3/15/2021; D.I. 2368 January 1, 2021 – $149,323.00 $103.54 $119,458.40 $10,354.00 $29,864.60 $ - January 31, 2021
3/17/2021; D.I. 2405 February 1, 2021 – $124,866.50 $2,041.19 $99,893.20 $2,041.19 $124,866.50 $2,044.19 February 28, 2021
ii Case 20-10343-LSS Doc 4262 Filed 05/17/21 Page 3 of 11
COMPENSATION AND HOURS BY PROFESSIONAL3 (Abuse Specific Attorneys)
Year of Ad- Position mission Hourly Total Name Total Compensation Area of Expertise / Years of Rate Hours4 Experience Bruce A. Griggs Shareholder 1989/32 $640.00 34.6 $22,144.00 Bruce G. Hearey Shareholder 1975/46 $565.00 1.4 $791.00 Charles E. McDonald, III Shareholder 1995/26 $460.00 0.9 $414.00 Gavin Martinson Shareholder 2005/16 $440.00 9.7 $4,268.00 Kelly S. Hughes Shareholder 2003/18 $475.00 2.7 $1,242.00 Russell C. McNamer Counsel 1992/29 $125.00 134 $16,750.00 Sean E. Manning Of Counsel 2001/20 $425.00 197 $87,665.00 Alexandria. Gardella Associate 2020/1 $240.00 1.1 $346.50 Kelci A. Davis Paralegal N/A $190.00 25.2 $4,788.00 Katie. Murray Paralegal N/A $150.00 47.3 $7,095.00
Total 453.9 $145,503.50
3 Effective January 1, 2021, Ogletree, Deakins, Nash, Smoak & Stewart, P.C. has implemented firm-wide rate in- creases. These rate increases are consistent with the Engagement Letter, which provides that the rates included therein are adjusted from time to time.
4 Ogletree, Deakins, Nash, Smoak & Stewart, P.C. charged the Debtors for 50% of non-working travel time in com- pliance with Local Rule 2016-2(d)(viii). Such reductions are reflected in the figures in this column.
iii Case 20-10343-LSS Doc 4262 Filed 05/17/21 Page 4 of 11
COMPENSATION AND EXPENSES BY PROJECT CATEGORY
Task Description Total Hours Total Compensation
Litigation/Claims 435.3 $139,845.50 Retention Issues 18.6 $5,658 TOTAL 453.9 $145,503.50
iv Case 20-10343-LSS Doc 4262 Filed 05/17/21 Page 5 of 11
EXPENSES BY CATEGORY
Category Amount Legal Support Services $81.19 Other (Immigration related) 11.24 TOTAL: $92.43
v Case 20-10343-LSS Doc 4262 Filed 05/17/21 Page 6 of 11
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: June 1, 2021 at 4:00 p.m. (ET)
THIRTEENTH MONTHLY APPLICATION OF OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C. FOR ALLOWANCE OF COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR THE PERIOD FROM MARCH 1, 2021 TO AND INCLUDING MARCH 31, 2021
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 tenth monthly application (this “Application”) requesting payment in the aggregate amount of $116,402.80 which is equal to (a) 80% of the $145,503. 50 of total com- pensation earned by Ogletree Deakins for its services to the Debtors during the period from March
1, 2021 to and including March 31, 2021 (the “Fee Period”) and (b) 100% of the $92.43 of neces- sary 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 fol- lows:
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. The amount requested includes certain fixed fee work for immi- gration matters.
Case 20-10343-LSS Doc 4262 Filed 05/17/21 Page 7 of 11
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
2 Case 20-10343-LSS Doc 4262 Filed 05/17/21 Page 8 of 11
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 Dea- kins 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 en- titled, 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 Applica- tion. 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, Ogle- tree Deakins requests payment in the aggregate amount of $116,402.80 which is equal to (a) 80% of the $145,503.50 of total compensation earned by Ogletree Deakins during the Fee Period for its
3 Case 20-10343-LSS Doc 4262 Filed 05/17/21 Page 9 of 11
services to the Debtors and (b) 100% of the $92.43 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 com- pensation earned by Ogletree Deakins during the Fee Period with respect to Phase 1 tasks (Litiga- tion/Claims). Attached hereto as Exhibit B is a detailed statement of the time expended and com- pensation earned by Ogletree Deakins during the Fee Period with respect to Phase 2 tasks (Reten- tion Issues). Ogletree Deakins’ professionals expended a total of 453.9 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 $92.43
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 $145,503.50.
4 Case 20-10343-LSS Doc 4262 Filed 05/17/21 Page 10 of 11
10. In accordance with section 330 of the Bankruptcy Code, the fees requested are rea- sonable 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 omit- ted 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]
5 Case 20-10343-LSS Doc 4262 Filed 05/17/21 Page 11 of 11
WHEREFORE, Ogletree Deakins requests payment in the aggregate amount of
(a) $116,402.80 which is equal to 80% of the $145,503.50 of total compensation earned by Ogle- tree Deakins during the Fee Period for its services to the Debtors, and (b) 100% of the $92.43 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 $116,495.23
Dated: May 17, 17 2021 Ogletree, Deakins, Nash, Smoak & Stewart, P.C. Austin, Texas /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
6 Case 20-10343-LSS Doc 4262-1 Filed 05/17/21 Page 1 of 3
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: June 1, 2021 at 4:00 p.m. (ET)
NOTICE OF THIRTEENTH MONTHLY APPLICATION OF OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C. FOR ALLOWANCE OF COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR THE PERIOD FROM MARCH 1, 2021 TO AND INCLUDING MARCH 31, 2021
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 Thirteenth Monthly Application of Ogletree, Deakins, Nash, Smoak & Stewart, P.C. for Allowance of Compensation and Reimbursement of Expenses for the Period from March 1, 2021 to and Including March 31, 2021 (the “Application”).
PLEASE TAKE FURTHER NOTICE that objections, if any, to the Application, must be: (a) filed with the Clerk of the Bankruptcy Court, 824 North Market Street, 3rd Floor, Wilmington, Delaware 19801, by June 1, 2021 at 4:00 p.m. (Eastern Time) (the “Objection Deadline”); and (b) 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: White & Case LLP, 111 South Wacker Drive, Chicago, Illinois 60606, 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 4262-1 Filed 05/17/21 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.
xii. Rucki Fee Review, LLC: 1111 Windon Drive, Wilmington, DE 19803, Attn: Justin Rucki.
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]
2 Case 20-10343-LSS Doc 4262-1 Filed 05/17/21 Page 3 of 3
Dated: May 17, 2021 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 Email: [email protected] [email protected] [email protected] [email protected]
– and –
WHITE & CASE LLP Jessica C. Lauria (admitted pro hac vice) 1221 Avenue of the Americas New York, New York 10020 Telephone: (212) 819-8200 Email: [email protected]
– and –
WHITE & CASE LLP Michael C. Andolina (admitted pro hac vice) Matthew E. Linder (admitted pro hac vice) Laura E. Baccash (admitted pro hac vice) Blair M. Warner (admitted pro hac vice) 111 South Wacker Drive Chicago, Illinois 60606 Telephone: (312) 881-5400 Email: [email protected] [email protected] [email protected] [email protected]
Attorneys for the Debtors and Debtors in Possession
3 Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 1 of 107
Exhibit A
Phase 1 Fees and Expense Itemization
Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 2 of 107
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 April 26, 2021 Telephone: (864) 241-1801 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 # 90416189 Client.Matter # 047657.000013
Re: BSA General Defense - Bankruptcy (Billiable)
For professional services rendered through March 31, 2021, in connection with the above-referenced matter as outlined on the attached detailed billing sheets:
Fees ...... $117,539.50 Expenses...... $81.19
Total Due This Bill...... $117,620.69
Fees Expenses Year-To-Date $156,369.70 $103.54 Life-To-Date $1,859,204.20 $2,414.12
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 4262-2 Filed 05/17/21 Page 3 of 107
Page 2 04/26/21 Bill No. 90416189 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)
For professional services rendered through March 31, 2021
Date Initials Stage Description Hours Amount 03/01/21 BAG PHASE1 Begin review of claims and cases 3.50 2,240.00 filed during the week of February 22. 03/01/21 SEM PHASE1 Email from counsel for Shriner's 0.10 44.50 International regarding the Heidi Plowman case in Arizona and communication with counsel for Sabbar Temple. 03/01/21 SEM PHASE1 Email exchange with California 0.20 89.00 defense counsel regarding BSA entities being represented by the filing of the Notice of Consent Order in the John Doe DZ 3 case. 03/01/21 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 an updated spreadsheet of BSA historical settlement data for review and potential use in the Historical Settlement project. 03/01/21 SEM PHASE1 Email exchange with California 0.20 89.00 defense counsel regarding getting the Consent Order Schedules amended to add the John Roe DZ 3 case. 03/01/21 SEM PHASE1 Review and prepare BSA historical 2.00 890.00 settlement data provided by BSA and pair down data for use in expanded research project. 03/01/21 SEM PHASE1 Begin revising the Ogletree BSA 4.50 2,002.50 Historical Settlement Spreadsheet with additional data from older BSA Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 4 of 107
Page 3 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount case resolutions. 03/01/21 SEM PHASE1 Email to White and Case with 0.20 89.00 updated Ogletree review of BSA historical settlements and discussion of observations from the same. 03/01/21 SEM PHASE1 Review letter from Connecticut 0.10 44.50 Yankee Council seeking a response to auditors regarding pending litigation. 03/01/21 SEM PHASE1 Email to Connecticut defense counsel 0.10 44.50 with Connecticut Yankee Council audit request and direction on the same. 03/01/21 SEM PHASE1 Email exchange with Grand Canyon 0.20 89.00 Council in Arizona regarding request for update on number of cases and plaintiffs against their council for tomorrow's board meeting. 03/01/21 SEM PHASE1 Email discussion with Missouri 0.40 178.00 defense counsel regarding updates and pleadings in the JFH matter regarding removal to federal court and suggestion of bankruptcy filed by Traveler's Insurance. 03/01/21 SEM PHASE1 Email exchange with California 0.20 89.00 defense counsel regarding inability to get a response from BSA regarding change of firm to Winston and Strawn. 03/01/21 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 documents obtained from the legislative tracking service about pending state statute of limitations revisions and need to update the Ogletree chart with the same. 03/01/21 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 request to update and continue the pending state statute of limitations change memo revision on a weekly basis. Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 5 of 107
Page 4 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount 03/01/21 SEM PHASE1 Review and collect data from Arizona 0.60 267.00 Litigation Tracking Spreadsheet regarding total number of lawsuits and plaintiffs related to the Grand Canyon Council. 03/01/21 SEM PHASE1 Detailed email to Grand Canyon 0.20 89.00 Council with details related to the number of lawsuits and plaintiffs with claims pending against the council. 03/01/21 SEM PHASE1 Email from White and case 0.40 178.00 requesting review of letter from Bates White to Coalition counsel regarding historical settlements. 03/01/21 SEM PHASE1 Email from Connecticut defense 0.10 44.50 counsel acknowledging audit request by the Connecticut Yankee Council and noting that they too received the same request. 03/01/21 SEM PHASE1 Review letter to BSA insurers 0.80 356.00 regarding valuation of claims prepared by Haynes and Boone and respond as necessary related to Ogletree section. 03/01/21 SEM PHASE1 Email from White and Case to advise 0.10 44.50 of potential Coalition Committee and TCC demand for production of historic BSA settlement material. 03/01/21 SEM PHASE1 Email exchange with White and Case 0.20 89.00 and counsel for Liberty Mutual regarding removal and stay issues in the JFH v. Mackey case in Missouri. 03/01/21 SEM PHASE1 Email from Arizona defense counsel 0.10 44.50 to plaintiff's counsel approving of waivers of service for filing in the Emmerich and Leibermann cases. 03/01/21 KAD PHASE1 Email exchange with Robyn Jungers 0.10 19.00 regarding quick action claim button and entering same in Riskonnect. 03/01/21 KAD PHASE1 Review email from Vanessa Savoy 0.10 19.00 regarding month-end reporting and Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 6 of 107
Page 5 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount entering claim in Riskonnect. 03/02/21 BAG PHASE1 Analyze updated new claims 2.50 1,600.00 spreadsheet and claims and cases filed during the week of February 22. 03/02/21 SEM PHASE1 Email discussion with White and 0.30 133.50 Case and Missouri defense counsel regarding need to conference about strategy for presenting BSA's position in the JFH case. 03/02/21 SEM PHASE1 Email exchange with Arizona defense 0.20 89.00 counsel regarding need for further discussion about BSA billing requirements on new cases. 03/02/21 SEM PHASE1 Email exchange with counsel for 0.20 89.00 Traveler's insurance and White and Case regarding further input on BSA insurer position on removal and stay in the JFH v. Mackey case in Missouri. 03/02/21 SEM PHASE1 Review potential need to put JFH 0.10 44.50 case on Consent Order Schedules. 03/02/21 SEM PHASE1 Email exchange with White and Case 0.20 89.00 seeking advise about whether the JFH case in Missouri needs to be added to the Consent Order Schedules. 03/02/21 SEM PHASE1 Email to Missouri defense counsel 0.10 44.50 regarding billing instructions for JFH case. 03/02/21 SEM PHASE1 Email from White and Case regarding 0.10 44.50 need to forward BSA historical settlement documents to BSA insurer. 03/02/21 SEM PHASE1 Review information obtained 0.50 222.50 regarding the BSA reorganization plan filed in the bankruptcy court yesterday and input on the same from plaintiff counsel and forward a summary of the same to the BSA. 03/02/21 SEM PHASE1 Telephone call from counsel for St. 0.30 133.50 Anne's Roman Catholic Church in Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 7 of 107
Page 6 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount New York regarding service of process in a new lawsuit filed in Suffolk County and the BSA Consent Order being filed to stay the case. 03/02/21 SEM PHASE1 Email exchange with Plaintiff's 0.20 89.00 counsel Martin Gould regarding need to obtain real Plaintiff names in Arizona and Illinois Pathway to Adventure & Three Fires claim. 03/02/21 SEM PHASE1 Continue to review BSA historical 0.30 133.50 settlement data and collecting information to update and revise the Ogletree Historical Settlement Spreadsheet. 03/02/21 SEM PHASE1 Conference call with Arizona defense 0.40 178.00 counsel regarding additional billing issues to discuss for new and previously billed cases. 03/02/21 SEM PHASE1 Email to BSA to set up a conference 0.10 44.50 call with Arizona defense counsel to address ongoing billing issues. 03/02/21 SEM PHASE1 Email discussion with White and 0.30 133.50 Case and Bates White regarding need for revisions to the BSA historical settlement spreadsheet to remove privileged information before producing to BSA insurers. 03/02/21 SEM PHASE1 Email exchange with counsel for St. 0.20 89.00 Anne's Catholic Church in New York with Nick Agostino lawsuit. 03/02/21 SEM PHASE1 Email exchange with New Mexico 0.20 89.00 defense counsel regarding the Court's notice of pending dismissal for lack of activity in the John Doe v. BSA and Our Lady of Guadalupe. 03/02/21 SEM PHASE1 Review Court's notice of pending 0.10 44.50 dismissal for lack of activity in the John Doe v. BSA and Our Lady of Guadalupe case in New Mexico. 03/02/21 SEM PHASE1 Review Nick Agostino lawsuit filed in 0.30 133.50 Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 8 of 107
Page 7 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount New York against the Suffolk County Council and collect details for the New York Litigation Tracking chart. 03/02/21 SEM PHASE1 Conference call with White and Case, 0.40 178.00 Bates White and Haynes and Boone regarding processing of historical BSA settlement data being produced to BSA insurers. 03/02/21 SEM PHASE1 Email to BSA and Suffolk County 0.30 133.50 Council regarding new Nick Agostino case details. 03/02/21 SEM PHASE1 Email to New York defense counsel 0.10 44.50 with Complaint and Service of Process documents received by St. Anne's Church and direction to file Notice of Consent Order for the Church and Suffolk County Council. 03/02/21 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 Notices of new lawsuits filed in New York for Plaintiff's RV, CC, and SC. 03/02/21 SEM PHASE1 Review RV Complaint filed in New 0.40 178.00 York and gather case details for the New York Litigation Tracking Chart. 03/02/21 SEM PHASE1 Review SC Complaint filed in New 0.30 133.50 York and gather case details for the New York Litigation Tracking Chart. 03/02/21 SEM PHASE1 Review CC Complaint filed in New 0.30 133.50 York and gather case details for the New York Litigation Tracking Chart. 03/02/21 SEM PHASE1 Email to Greater New York Councils 0.40 178.00 to seek information about the new RV, SC, and CC cases. 03/02/21 SEM PHASE1 Email from Haynes and Boone with 0.10 44.50 multiple responses from BSA insurers regarding the BSA bankruptcy disclosures and plan and request for input on the same related to Ogletree data. 03/02/21 SEM PHASE1 Review revised BSA historical 0.20 89.00 settlement data being presented to Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 9 of 107
Page 8 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount insurers and provide input on the same. 03/02/21 SEM PHASE1 Email from White and case with 0.20 89.00 correspondence with plaintiffs' counsel regarding the preliminary injunction application to the City of Rye case and respond to the same. 03/02/21 SEM PHASE1 Review letter from Century Indemnity 0.90 400.50 Company in response to BSA filed bankruptcy plan and formulate a response related to the Ogletree related issues. 03/02/21 SEM PHASE1 Conference call with White and Case 0.30 133.50 and Missouri defense counsel to discuss strategy and details of a potential BSA response in the JFH v. Mackey case. 03/02/21 SEM PHASE1 Complete review of letters from BSA 0.60 267.00 insurers in response to the BSA proof of claim valuation guide presented to them by Bates White, Haynes and Boone and White and Case. 03/02/21 SEM PHASE1 Email exchange with Haynes and 0.20 89.00 Boone regarding notes for use in a formal response to BSA Insurers related to the objection to the proof of claim valuation model. 03/02/21 SEM PHASE1 Email exchange with Greater New 0.20 89.00 York Councils regarding details of the named Learning for Life entity in the new NYPD Explorer cases filed there. 03/02/21 SEM PHASE1 Email from Bates White advising they 0.10 44.50 have uploaded an updated version of the standardized Tranche 4 data that contain only a single record for each individual claimant that made a timely filing to the BSA Data Room. 03/02/21 SEM PHASE1 Email discussion with Denver Area 0.30 133.50 Council and the council attorney regarding receipt of the Ogletree litigation hold letter and duties to Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 10 of 107
Page 9 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount comply with the same. 03/02/21 KAD PHASE1 Email exchange with Audra 0.10 19.00 Kalinowski regarding third notices of consent order filed in New York cases. 03/02/21 KAD PHASE1 Enter new claim in Riskonnect for 1.40 266.00 lawsuit filed by J.F.H. against BSA's insurers. 03/02/21 KAD PHASE1 Analyze lawsuit filed by J.F.H. and 0.20 38.00 prior case documents in preparation of entering same in Riskonnect. 03/02/21 KAD PHASE1 Email exchange with Sean Manning 0.10 19.00 and Erin Rosenberg regarding J.F.H. case and adding same to schedules 1 and 2. 03/02/21 KAD PHASE1 Analyze lawsuit filed by Raymond F. 0.20 38.00 Ptak, II (AZ) in preparation of entering same in Riskonnect. 03/02/21 KAD PHASE1 Enter new claim in Riskonnect for 1.00 190.00 lawsuit filed by Raymond F. Ptak, II (AZ). 03/02/21 KAD PHASE1 Analyze lawsuit filed by Robert L. 0.20 38.00 Martin (AZ) in preparation of entering same in Riskonnect. 03/02/21 KAD PHASE1 Enter new claim in Riskonnect for 1.00 190.00 lawsuit filed by Robert L. Martin (AZ). 03/02/21 KAD PHASE1 Analyze lawsuit filed by John PA 1 0.20 38.00 Doe (AZ) in preparation of entering same in Riskonnect. 03/02/21 KAD PHASE1 Enter new claim in Riskonnect for 1.00 190.00 lawsuit filed by John PA 1 Doe (AZ). 03/02/21 KAD PHASE1 Analyze lawsuit filed by John Doe PA 0.20 38.00 15 (AZ) in preparation of entering same in Riskonnect. 03/02/21 KAD PHASE1 Enter new claim in Riskonnect for 1.00 190.00 lawsuit filed by John Doe PA 15 (AZ). 03/02/21 KAD PHASE1 Telephone call and instant message 0.20 38.00 Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 11 of 107
Page 10 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount with Robyn Jungers regarding entering AZ claim in Riskonnect. 03/02/21 KAD PHASE1 Draft email to outside counsel 0.20 38.00 regarding Chubb payments and denial of coverage. 03/02/21 KAD PHASE1 Review notice of inactivity filed in 0.10 19.00 John Doe (NM) case and email from Kathleen Russell regarding same. 03/02/21 KAD PHASE1 Email exchanges with Anna Kutz and 0.20 38.00 Robyn Jungers regarding email to defense counsel regarding Chubb coverage and payments. 03/02/21 KAD PHASE1 BSA team conference call regarding 0.50 95.00 status of bankruptcy case and projects. 03/02/21 KJM PHASE1 Analyze lawsuit filed by John A.C. 0.50 75.00 Doe (AZ) in preparation for entering same in Riskonnect. 03/02/21 KJM PHASE1 Enter new claim in Riskonnect for 0.80 120.00 lawsuit filed by A.C. Doe (AZ). 03/02/21 KJM PHASE1 Enter multi-plaintiff lawsuit filed by 1.20 180.00 John Does 1-65 in AZ. (John Doe 1). 03/02/21 KJM PHASE1 Analyze and review of AZ tracking 0.20 30.00 spreadsheet in addition to multi- plaintiff lawsuit filed by John Does 1- 65 (Doe 1) in preparation for entering into Riskonnect. 03/03/21 BAG PHASE1 Review email and Appellant's Brief 0.50 320.00 received from defense counsel in the consolidated McArthur cases (GA). 03/03/21 BAG PHASE1 Exchange email with Erin Rosenberg 0.20 128.00 regarding status of Guam cases and the court's request for additional briefing. 03/03/21 BAG PHASE1 Telephone conference with Guam 0.50 320.00 defense counsel regarding status of the cases and the courts request for additional briefing. Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 12 of 107
Page 11 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount 03/03/21 BAG PHASE1 Follow up email exchanges with Erin 0.30 192.00 Rosenberg and Mike Andolina regarding status of the Guam cases and the courts request for additional briefing. 03/03/21 SEM PHASE1 Email from Greater New York 0.10 44.50 Councils with information and post rosters related to the three new Police Explorer cases filed in New York. 03/03/21 SEM PHASE1 Email from Georgia defense counsel 0.10 44.50 with McArthur Brief of Appellants from dismissal of three church defendants in pending BSA case. 03/03/21 SEM PHASE1 Extensive email discussion with BSA 0.40 178.00 and Greater New York Councils regarding the LFL entity named in the new Police Explorer cases there. 03/03/21 SEM PHASE1 Draft response points to 10 page BSA 3.20 1,424.00 insurer objection to BSA valuation guide and Ogletree statute of limitation analysis for Haynes and Boone. 03/03/21 SEM PHASE1 Email exchange with the Suffolk 0.20 89.00 County Council regarding the ability for plaintiffs to continue filing lawsuits after the bankruptcy claim bar date. 03/03/21 SEM PHASE1 Email to Haynes and Boone with 0.10 44.50 Ogletree input on Century Insurance Company's objections to the BSA statute of limitations and valuation analysis. 03/03/21 SEM PHASE1 Email exchange with Illinois defense 0.20 89.00 counsel regarding upcoming status conference in the Haywood case and update on bankruptcy case. 03/03/21 SEM PHASE1 Email from Suffolk County Council 0.10 44.50 with information related to new Nick Agostino case. 03/03/21 SEM PHASE1 Email from Las Vegas Area Council 0.10 44.50 Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 13 of 107
Page 12 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount with notice of service of process in the John Does #1 and #2 and John Doe #1 cases. 03/03/21 SEM PHASE1 Telephone call from Georgia defense 0.20 89.00 counsel to discuss bankruptcy status and potential for McArthur appeal to resolve pending BSA abuse cases in Georgia. 03/03/21 SEM PHASE1 Continue reviewing historical BSA 2.00 890.00 settlement data and revising the Ogletree Historical Settlement Analysis Spreadsheet with the same. 03/03/21 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 new Police Explorer cases filed in New York. 03/03/21 SEM PHASE1 Further email discussion with White 0.30 133.50 and Case and Missouri defense counsel regarding information obtained from Liberty Mutual counsel and suggestion of bankruptcy filing strategy and details in the JFH case in Missouri. 03/03/21 SEM PHASE1 Email discussion with White and 0.50 222.50 Case and Guam defense counsel regarding the need to file a response to the Court's order for briefing in the Guam cases and review said draft filing. 03/03/21 SEM PHASE1 Email from White and Case to advise 0.10 44.50 we do not need to add the JFH case in Missouri to the Consent Order Schedules. 03/03/21 SEM PHASE1 Review Court Order in Guam for 0.20 89.00 briefing on the issue of subject matter jurisdiction and related correspondence from Guam defense counsel with the same. 03/03/21 SEM PHASE1 Email from BSA with information 0.10 44.50 related to John AC Doe case in Arizona. Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 14 of 107
Page 13 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount 03/03/21 KAD PHASE1 Review email from Anna Kutz 0.10 19.00 regarding three new lawsuits filed in New York. 03/03/21 KAD PHASE1 Review multiple emails between 0.20 38.00 Robyn Jungers and various defense counsel regarding Chubb payments and coverage. 03/04/21 BAG PHASE1 Telephone conference with S. 0.30 192.00 Manning, K. Davis and K. Murray to discuss status of all matters and pending projects to be completed. 03/04/21 SEM PHASE1 Email exchange with White and Case 0.20 89.00 regarding decision related to handling JFH v. Mackey Suggestion of Bankruptcy. 03/04/21 SEM PHASE1 Email from White and Case with filed 0.10 44.50 BSA response to the Court's Order for Briefing on Subject Matter Jurisdiction and reference to the Stay of Litigation. 03/04/21 SEM PHASE1 Conference call with BSA, White and 0.90 400.50 Case and Bates White regarding production of unit rosters to Tort Claims Committee and process for handling the same. 03/04/21 SEM PHASE1 Review process for adding new 0.20 89.00 claims to the Weekly new claims report and Consent Order Schedules. 03/04/21 SEM PHASE1 Review service of process documents 0.10 44.50 received from the Las Vegas Area Council and update the Arizona Litigation Tracking Chart with the same. 03/04/21 SEM PHASE1 Email to Arizona defense counsel 0.20 89.00 with service of process documents received from the Las Vegas Area Council with details of the cases and direction to file the Notice of Consent Order. 03/04/21 SEM PHASE1 Revise and update New York 0.10 44.50 Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 15 of 107
Page 14 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount Litigation Tracking chart with information related to the Nick Agostino case provided by the Suffolk County Council. 03/04/21 SEM PHASE1 Review Post rosters and other 0.50 222.50 information and documents received from the Greater New York Councils related to the Police Explorer cases in New York and update the New York Litigation Tracking chart with same. 03/04/21 SEM PHASE1 Email to BSA advising that New York 0.10 44.50 Police Explorer Plaintiff SC does not appear on Post rosters. 03/04/21 SEM PHASE1 Email from BSA with information 0.10 44.50 related to John AC Doe case in Arizona. 03/04/21 SEM PHASE1 Update and Revise Arizona Litigation 0.10 44.50 Tracking Chart with information obtained from BSA related to John SC Doe case. 03/04/21 SEM PHASE1 Email to Haynes and Boone with 0.10 44.50 update to yesterday's memo on proof of claim valuation and statute of limitations analysis. 03/04/21 SEM PHASE1 Email to New York defense counsel 0.10 44.50 seeking a copy of the filed Notice of Consent Order in the new Nicholas Agostino case to send to chartered organization counsel. 03/04/21 SEM PHASE1 Review 35 page McArthur Brief in 0.80 356.00 Georgia appeal matter related to dismissal of chartered organizations on statute of repose and RICO grounds in underlying BSA cases as it impacts potential dismissal of the BSA abuse matters. 03/04/21 SEM PHASE1 Email from BSA with clarified 0.20 89.00 information related to the CS Police Explorer case in New York and revise the New York Litigation Tracking Chart accordingly. Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 16 of 107
Page 15 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount 03/04/21 SEM PHASE1 Conference call with BSA and 0.50 222.50 Arizona defense counsel to work out a finalized plan for billing multi- plaintiff cases and recreated billing from January and February. 03/04/21 SEM PHASE1 Continue to review historical BSA 1.40 623.00 settlement data and collecting same for the Ogletree BSA Settlement Valuation Spreadsheet. 03/04/21 SEM PHASE1 Review email from Liberty Mutual 0.10 44.50 counsel regarding Court ordered mediation in the JFH case in Missouri. 03/04/21 SEM PHASE1 Conference call with White and Case 0.50 222.50 and Missouri defense counsel regarding status of JFH case, handling BSA response and potential mediation matters. 03/04/21 SEM PHASE1 Review Plaintiff JFH's 50 page 0.80 356.00 Motion for Abstention and Remand and related pleadings. 03/04/21 SEM PHASE1 Email exchange with White and Case 0.20 89.00 regarding data possessed by Ogletree related to the real Plaintiff names in litigation and connection to proofs of claim. 03/04/21 SEM PHASE1 Email exchange with White and Case 0.20 89.00 regarding ability for Ogletree to produce copies of all abuse lawsuit complaints. 03/04/21 SEM PHASE1 Review proof of claim data 0.20 89.00 possessed by Ogletree and advise White and Case of the same for potential use in new projects. 03/04/21 SEM PHASE1 Email from New York defense 0.20 89.00 counsel with Notice of Entry filed in the Nick Agostino case and forward same to counsel for St. Anne's Catholic Church. 03/04/21 SEM PHASE1 Email from BSA with follow-up 0.10 44.50 Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 17 of 107
Page 16 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount confirmation of finalized billing plan for Arizona lawsuits. 03/04/21 SEM PHASE1 Email exchange with Hawaii defense 0.20 89.00 counsel regarding Court ordered status report filing deadline and information to include in the same. 03/04/21 SEM PHASE1 Review email from White and Case to 0.10 44.50 BSA updating on the BSA response to filing in the JFH matter in Missouri. 03/04/21 SEM PHASE1 Email exchange with White and Case 0.20 89.00 regarding setting up a share file to upload abuse complaints for further review and compare to proofs of claim. 03/04/21 KAD PHASE1 Email exchanges with Jennifer 0.10 19.00 Nichols and Sean Manning regarding Anonymous CC, SC and RV complaints. 03/04/21 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 and Sean Manning regarding John AC Doe. 03/04/21 KAD PHASE1 Review email from Erin Rosenberg 0.10 19.00 regarding J.F.H. lawsuit and not adding same to schedules. 03/04/21 KAD PHASE1 Analyze lawsuit filed by John Doe PA 0.20 38.00 13 (AZ) in preparation of entering same in Riskonnect. 03/04/21 KAD PHASE1 Enter new claim in Riskonnect for 1.00 190.00 lawsuit filed by John Doe PA 13 (AZ). 03/04/21 KAD PHASE1 BSA team conference call to discuss 0.50 95.00 outstanding projects and assignments. 03/04/21 KAD PHASE1 Revise Schedules 1 and 2 to reflect 2.70 513.00 newly received lawsuits. 03/04/21 KAD PHASE1 Analyze lawsuit filed by John Doe PA 0.20 38.00 12 (AZ) in preparation of entering same in Riskonnect. 03/04/21 KAD PHASE1 Enter new claim in Riskonnect for 1.00 190.00 Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 18 of 107
Page 17 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount lawsuit filed by John Doe PA 12 (AZ). 03/04/21 KAD PHASE1 Email exchange with Nicole Capece 0.10 19.00 regarding billing information on new (NY) lawsuit. 03/04/21 KAD PHASE1 Analyze lawsuit filed by Kevin Monturi 0.20 38.00 (AZ) in preparation of entering same in Riskonnect. 03/04/21 KAD PHASE1 Enter new claim in Riskonnect for 1.00 190.00 lawsuit filed by Kevin Monturi (AZ). 03/04/21 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding John PA Doe 1. 03/04/21 KJM PHASE1 Email exchange with Erin Rosenberg 0.10 15.00 at White and Case regarding post- petition Complaints. 03/04/21 KJM PHASE1 Review email communication from S. 0.10 15.00 Manning regarding post-petition Complaints and request to create ShareFile folder regarding same. 03/05/21 BAG PHASE1 Review email analysis regarding 0.20 128.00 application of charitable immunity doctrine in multiple jurisdictions. 03/05/21 SEM PHASE1 Review information regarding BSA 0.20 89.00 bankruptcy case filing granting BSA until April 2, 2021 to respond to the Tort Claims Committee adverse action over BSA assets and send information of the same to BSA. 03/05/21 SEM PHASE1 Email from White and Case seeking 0.10 44.50 Ogletree review of OMNI adversary service list from the BSA Motion to Extend the Preliminary Injunction. 03/05/21 SEM PHASE1 Review statute of limitations 0.40 178.00 information for Ohio for update of the Ogletree 50 State review and analysis. 03/05/21 SEM PHASE1 Research Utah and Virginia 0.80 356.00 charitable immunity doctrine and update the Ogletree 50 State statute of limitations memorandum as Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 19 of 107
Page 18 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount necessary. 03/05/21 SEM PHASE1 Email to Haynes and Boone 0.10 44.50 regarding research and update on charitable immunity laws referenced by Century Insurance. 03/05/21 SEM PHASE1 Email exchange with White and Case 0.20 89.00 regarding request for limitation of BSA historical settlement data to LDS claims. 03/05/21 SEM PHASE1 Email exchange with White and Case 0.20 89.00 and New York defense counsel regarding the BSA affirmation for filing in the City of Rye case and additional information to update on the same. 03/05/21 SEM PHASE1 Email to BSA seeking historical 0.10 44.50 settlement data specifically related to the LDS Church in response to request from White and Case. 03/05/21 SEM PHASE1 Emails from BSA and Haynes and 0.20 89.00 Boone agreeing to BSA plan of response in the JFH case in Missouri. 03/05/21 SEM PHASE1 Conference call with plaintiff's 0.40 178.00 counsel Martin Gould regarding Plaintiffs in Arizona and Illinois and location of records during the stay of litigation. 03/05/21 SEM PHASE1 Email to Illinois local councils in 0.10 44.50 search of records related to Martin Gould client in John Doe claim. 03/05/21 SEM PHASE1 Email from White and Case to 0.10 44.50 Missouri defense counsel with finalized Suggestion of Bankruptcy and authorization for filing in the JFH case. 03/05/21 SEM PHASE1 Email from BSA with revised 0.10 44.50 historical settlement spreadsheet to include LDS Church information. 03/05/21 SEM PHASE1 Email to White and Case regarding 0.10 44.50 LDS Church settlement data and Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 20 of 107
Page 19 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount formatting a LDS only spreadsheet. 03/05/21 SEM PHASE1 Update and revise Arizona Litigation 0.10 44.50 Tracking chart with information related to the real Plaintiff's name for Martin Gould case. 03/05/21 SEM PHASE1 Revise and process historical 0.50 222.50 settlement data received from BSA related to the LDS Church and prepare same for comparison to the Ogletree historical settlement spreadsheet to incorporate the same. 03/05/21 SEM PHASE1 Review information provided by BSA 0.20 89.00 regarding the David Rausch case in Arizona and update the Arizona Litigation Tracking chart with the same. 03/05/21 SEM PHASE1 Email discussion with Missouri 0.40 178.00 defense counsel and White and Case regarding need to file an entry of appearance and be made a part in the JFH case before being able to file the Suggestion of Bankruptcy on behalf of BSA. 03/05/21 SEM PHASE1 Emails from Pathway to Adventure 0.20 89.00 Council with documents and information related to the John Doe claim against Reid Weinbrenner. 03/05/21 SEM PHASE1 Email exchange with White and Case 0.20 89.00 regarding requirement for Missouri defense counsel to file an entry of appearance and become a represented party in the JFH case in order to file the Suggestion of Bankruptcy. 03/05/21 SEM PHASE1 Email to White and Case to advise 0.10 44.50 there are no additional parties to add to the adverse service list. 03/05/21 SEM PHASE1 Review BSA historical settlement 1.80 801.00 data related to LDS Church settlements and update and revise Ogletree BSA Historical Settlement Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 21 of 107
Page 20 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount Spreadsheet with information obtained from the same. 03/05/21 SEM PHASE1 Email to White and Case with 0.10 44.50 Ogletree BSA historical settlement spreadsheet sorted with LDS Church matters. 03/05/21 SEM PHASE1 Email exchange with White and Case 0.20 89.00 regarding most updated Consent Order Schedules and handling of the same after Kelci Davis at Ogletree and Krista McDonald at White and Case both go on maternity leave. 03/05/21 SEM PHASE1 Review Weekly New Claims Report 0.10 44.50 to ensure all new claims received this week have been handled. 03/05/21 SEM PHASE1 Email from Missouri defense counsel 0.10 44.50 with filed Suggestion of Bankruptcy in the JFH matter. 03/05/21 SEM PHASE1 Review documents and information 0.30 133.50 received from the Patriots Path Council related to the new John Doe claim received from Martin Gould. 03/05/21 SEM PHASE1 Email discussion with California 0.40 178.00 defense counsel and BSA regarding the Hueston Hennigan retainer matter. 03/05/21 SEM PHASE1 Email exchange with Crossroads of 0.20 89.00 the West Council regarding service of process in the Patey case pending in Arizona. 03/05/21 SEM PHASE1 Review service of process documents 0.20 89.00 received from the Crossroads of the West Council in the Patey case pending in Arizona and revise Arizona Litigation Tracking chart accordingly. 03/05/21 SEM PHASE1 Email to Arizona defense counsel 0.20 89.00 with service of process documents received in the Patey case and details of the contents of those Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 22 of 107
Page 21 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount documents. 03/05/21 SEM PHASE1 Email exchange with New York 0.20 89.00 defense counsel regarding Affidavit in support of Stay of Litigation to file in City of Rye case. 03/05/21 SEM PHASE1 Review Affidavit in Support of Stay of 0.10 44.50 Litigation to file in City of Rye case. 03/05/21 SEM PHASE1 Email with BSA regarding new LDS 0.20 89.00 claim in Illinois related to alleged perpetrator Reid Weinbrenner. 03/05/21 KAD PHASE1 Analyze lawsuit filed by David 0.20 38.00 Rausch (AZ) in preparation of entering same in Riskonnect. 03/05/21 KAD PHASE1 Enter new claim in Riskonnect for 1.00 190.00 lawsuit filed by David Rausch (AZ). 03/05/21 KAD PHASE1 Prepare weekly new claims report. 0.80 152.00 03/05/21 KAD PHASE1 Email White & Case, Alvarez Marsal, 0.10 19.00 BSA and Monica Blacker regarding weekly new abuse claims report. 03/05/21 KAD PHASE1 Email exchange with Eric Moats 0.10 19.00 regarding adversary service list. 03/05/21 KAD PHASE1 Analyze lawsuit filed by CR Doe (AZ) 0.20 38.00 in preparation of entering same in Riskonnect. 03/05/21 KAD PHASE1 Enter new claim in Riskonnect for 1.00 190.00 lawsuit filed by CR Doe (AZ). 03/05/21 KAD PHASE1 Compare adversary service list to 1.60 304.00 newly received lawsuits and identify any new parties that need to be added. 03/05/21 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding David Rausch lawsuit. 03/05/21 KAD PHASE1 Email exchange with Krista McDonald 0.10 19.00 regarding updated Schedules 1 and 2. 03/05/21 KAD PHASE1 Analyze lawsuit filed by GB Doe (AZ) 0.20 38.00 in preparation of entering same in Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 23 of 107
Page 22 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount Riskonnect. 03/05/21 KAD PHASE1 Enter new claim in Riskonnect for 1.00 190.00 lawsuit filed by GB Doe (AZ). 03/05/21 KAD PHASE1 Analyze lawsuit filed by Raymond 0.20 38.00 Witt (AZ) in preparation of entering same in Riskonnect. 03/05/21 KAD PHASE1 Enter new claim in Riskonnect for 1.00 190.00 lawsuit filed by Raymond Witt (AZ). 03/05/21 KJM PHASE1 Create a shared folder and begin 0.70 105.00 research of Complaints filed in New York and California. 03/06/21 SEM PHASE1 Email exchange with White and Case 0.20 89.00 regarding formatting of the Ogletree BSA historical Settlement Spreadsheet for excluding Non-LDS claims before sending to the LDS counsel. 03/06/21 SEM PHASE1 Email exchange with New York 0.20 89.00 defense counsel and White and Case regarding additional bankruptcy code language to add to BSA Affirmation to file in the City of Rye case. 03/06/21 SEM PHASE1 Email exchange with Morris Nichols 0.20 89.00 regarding the currentness and accuracy of the OMNI adversary service list. 03/06/21 SEM PHASE1 Email from Arizona defense counsel 0.10 44.50 regarding plan for prioritizing the filing of Notices of Consent Orders in the Arizona cases being served on local councils. 03/07/21 KJM PHASE1 Email exchange with C. Tuffey at 0.10 15.00 Case & White regarding post-pettion Complaints. 03/08/21 BAG PHASE1 Review 3/5/21 new claims 2.00 1,280.00 spreadsheet and begin review of new claims and cases received subsequent to February 26. 03/08/21 BAG PHASE1 Review and respond to email from 0.20 128.00 Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 24 of 107
Page 23 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount Anna Kutz regarding retention of defense firm for California cases. 03/08/21 SEM PHASE1 Email exchange with White and Case 0.20 89.00 and New York defense counsel regarding final direction on the City of Rye matter. 03/08/21 SEM PHASE1 Email with BSA regarding the Illinois 0.20 89.00 John Doe letter of representation from Martin Gould and adding same tot he BSA claims tracking data. 03/08/21 SEM PHASE1 Email discussion with Morris Nichols 0.30 133.50 regarding request to verify all OMNI adverse service addresses. 03/08/21 SEM PHASE1 Further email discussion with Morris 0.30 133.50 Nichols about last month's updating of the adversary service list with OMNI and currentness of the same. 03/08/21 SEM PHASE1 Research Arizona proof of claim to 0.20 89.00 locate additional details about Martin Gould's John Doe client's lawsuit. 03/08/21 SEM PHASE1 Email to Plaintiff's counsel Martin 0.20 89.00 Gould regarding information related to his clients in Arizona and Illinois. 03/08/21 SEM PHASE1 Email with BSA regarding information 0.20 89.00 about Greater New York Councils Scout Executive. 03/08/21 SEM PHASE1 Research latest legislative review of 1.50 667.50 potential changes to state statute of limitations and update the Ogletree memorandum regarding the same. 03/08/21 SEM PHASE1 Email to BSA, White and Case and 0.10 44.50 Ogletree recipients with the Updated Ogletree State Statute of Limitation Memorandum, per direction of Steve McGowan. 03/08/21 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 change of defense counsel in California matters. 03/08/21 SEM PHASE1 Email from White and Case 0.10 44.50 Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 25 of 107
Page 24 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount requesting that certain non-BSA cases that name the LDS Church be added to the Consent Order Schedules on the next Amendment. 03/08/21 SEM PHASE1 Email exchange with Missouri 0.20 89.00 defense counsel and White and Case regarding contact from Travelers Insurance counsel to discuss BSA response in the JFH matter. 03/08/21 SEM PHASE1 Email from Seneca Waterways 0.20 89.00 counsel regarding service of process in the Guy Forman case and information related to the coordinating BSA proof of claim. 03/08/21 SEM PHASE1 Email exchange with LDS Church 0.20 89.00 counsel seeking Complaints to add information from for the BSA Consent Order Schedules. 03/08/21 SEM PHASE1 Review Guy Forman case filed in 0.30 133.50 New York and collect data regarding the Plaintiff's claims for the New York Litigation Tracking Chart. 03/08/21 SEM PHASE1 Email to New York defense counsel 0.20 89.00 and BSA with Guy Forman lawsuit and details of the same. 03/08/21 SEM PHASE1 Continue reviewing BSA historical 1.80 801.00 settlement data involving the LDS Church and continue updating and revising the Ogletree BSA Historical Settlement Spreadsheet with the same. 03/08/21 SEM PHASE1 Email from Arizona defense counsel 0.20 89.00 with Order Granting Stay in the William King case and forward same to Grand Canyon Council. 03/08/21 SEM PHASE1 Email discussion with BSA and New 0.30 133.50 York defense counsel regarding the issues with CHUBB and directions for billing in the new Guy Forman case. 03/08/21 SEM PHASE1 Review information received from 0.20 89.00 Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 26 of 107
Page 25 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount BSA regarding the new Guy Forman case in the Seneca Waterways Council and update the New York Litigation Tracking Chart accordingly. 03/08/21 SEM PHASE1 Review internal BSA File for alleged 0.60 267.00 perpetrator and victims proof of claim in the Guy Forman case in New York. 03/08/21 SEM PHASE1 Email exchange with White and Case 0.40 178.00 regarding urgent need to update the Consent Order Schedules with the LDS church case information received today. 03/08/21 SEM PHASE1 Revise BSA Consent Order 0.30 133.50 Schedules to include LDS Church cases added today. 03/08/21 SEM PHASE1 Email to White and Case with 0.10 44.50 updated Amended Consent Order Schedules with the LDS and Seneca Waterways Council cases added. 03/08/21 SEM PHASE1 Email to BSA with information 0.10 44.50 obtained from review of Guy Forman's proof of claim and perpetrator's internal BSA file. 03/08/21 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 and Sean Manning regarding R.W. (IL) claim. 03/08/21 KAD PHASE1 Email exchanges with Eric Moats and 0.30 57.00 Sean Manning regarding adversary service list. 03/08/21 KAD PHASE1 Email exchange with Robyn Jungers 0.20 38.00 regarding North Carolina defense counsel and update Riskonnect claims with same. 03/08/21 KAD PHASE1 Email exchange with Matthew Linder 0.10 19.00 and Sean Manning regarding new cases to add to Schedules 1 and 2. 03/08/21 KJM PHASE1 Email to E. Rosenberg, D. Hirshorn 0.70 105.00 and C. Tuffey regarding AZ Complaints research results and access to ShareFIle folder regarding Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 27 of 107
Page 26 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount same. 03/08/21 KJM PHASE1 Continue to research Complaints 0.90 135.00 requested by E. Rosenberg and send results via email to E. Rosenberg at Case and White regarding same. 03/08/21 KJM PHASE1 Continue to research NJ Complaints 0.60 90.00 and send email to E. Rosenberg at Case and White a share folder containing results of same. 03/08/21 KJM PHASE1 Research GA and HI Complaints and 0.30 45.00 send email to E. Rosenberg at Case and White a share folder containing results of same. 03/08/21 KJM PHASE1 Research MT, MO and HI Complaints 0.60 90.00 and send to E. Rosenberg, D. Hirshorn and C. Tuffey at Case and White regarding same. 03/08/21 KJM PHASE1 Complete research of Complaints and 0.40 60.00 send final results via email to E. Rosenberg, S. Manning, C. Tuffey and D. Hirshorn at Case and White regarding same. 03/08/21 KJM PHASE1 Review and respond to email from C. 0.10 15.00 Tuffey regarding post-petition Complaint research. 03/09/21 BAG PHASE1 Review updates SOL memorandum. 0.30 192.00 03/09/21 BAG PHASE1 Email exchange with Sean Manning 0.10 64.00 regarding updated SOL memorandum. 03/09/21 BAG PHASE1 Telephone conference with Steve 0.30 192.00 McGowan regarding overall strategy and recent developments. 03/09/21 BAG PHASE1 Internal team meeting S. Manning 0.30 192.00 and K. Murray to discuss overall status and recent developments. 03/09/21 BAG PHASE1 Telephone conference with R. 0.20 128.00 Chapman regarding overall status and recent developments. Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 28 of 107
Page 27 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount 03/09/21 BAG PHASE1 Continue review of new claims and 1.50 960.00 cases received subsequent to 2/25/21. 03/09/21 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 sending cases like the new Guy Forman matter to Bates White and seeking advice from White and Case about the same. 03/09/21 SEM PHASE1 Email exchange with BSA 0.20 89.00 Membership Standards regarding the Guy Forman case in New York. 03/09/21 SEM PHASE1 Email to Seneca Waterways Council 0.10 44.50 seeking troop rosters related to the Guy Forman case. 03/09/21 SEM PHASE1 Email to White and Case regarding 0.20 89.00 the Guy Forman case in New York specifically, but skeptical cases generally and possible involvement of Bates White. 03/09/21 SEM PHASE1 Email exchange with White and Case 0.20 89.00 regarding handling skeptical cases. 03/09/21 SEM PHASE1 Revise New York Litigation Tracking 0.10 44.50 Chart to note that the Guy Forman case is suspicious. 03/09/21 SEM PHASE1 Revise Ogletree BSA Historical 0.30 133.50 Settlement Spreadsheet to be LDS Church case specific and send same to White and Case. 03/09/21 SEM PHASE1 Conference call with Missouri 0.60 267.00 defense counsel and White and Case regarding latest developments in the JFH Matter, strategy in the BSA response to the same and positions related to us by the BSA Insurance carriers. 03/09/21 SEM PHASE1 Email exchange with White and Case 0.20 89.00 regarding limited spreadsheet details to send to LDS Church counsel today. 03/09/21 SEM PHASE1 Review limited settlement data sent 0.10 44.50 Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 29 of 107
Page 28 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount to Tort Claims Committee and correspondence with same from White and Case. 03/09/21 SEM PHASE1 Email from BSA advising Guy 0.20 89.00 Forman is not on the Troop 356 rosters and email Seneca Waterways seeking Troop 26 rosters from the same time period. 03/09/21 SEM PHASE1 Research Ogletree files to locate 0.30 133.50 James Doe lawsuit filed in North Carolina in November 2020 to send to White and Case for review and collection of data for bankruptcy proofs of claim comparison. 03/09/21 SEM PHASE1 Email exchange with White and Case 0.20 89.00 and Missouri defense counsel regarding communication with the court about BSA participation in conferences. 03/09/21 SEM PHASE1 Email exchange with BSA and 0.20 89.00 Northern New Jersey Council regarding service of the new PC-42 Doe case. 03/09/21 SEM PHASE1 Review new PC-42 Doe case filed in 0.30 133.50 New Jersey and collect details of the same for seeking related documents and sending to local defense counsel. 03/09/21 SEM PHASE1 Email to Northern New Jersey 0.10 44.50 Council with details of the PC-42 Doe case and request for records related to the same. 03/09/21 SEM PHASE1 Email to New Jersey defense counsel 0.10 44.50 with service of process documents received by the Northern New Jersey Council in the PC-42 Doe case and direction to foe the BSA Notice of Consent Order. 03/09/21 SEM PHASE1 Email from Missouri defense counsel 0.10 44.50 noting information related to the JFH conference and mediator. Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 30 of 107
Page 29 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount 03/09/21 SEM PHASE1 Conference call with White and Case 0.40 178.00 regarding removal of the City of Rye case from the bankruptcy stay and Consent Order Schedules. 03/09/21 SEM PHASE1 Review documentary prepared from 0.80 356.00 BSA abuse victim regarding abuse in the LDS Church and BSA. 03/09/21 SEM PHASE1 Email summary of BSA/LDS Church 0.10 44.50 abuse documentary to BSA for information and review. 03/09/21 SEM PHASE1 Email exchange with Seneca 0.20 89.00 Waterways Council regarding troop rosters related to Arthur Harper and Guy Forman and research related to the same. 03/09/21 SEM PHASE1 Email exchange with Arizona defense 0.20 89.00 counsel regarding need to file Third Notices of Consent Orders verses waiting to file Forth Notices of Consent Order. 03/09/21 SEM PHASE1 Email exchange with Arizona 0.20 89.00 Plaintiff's counsel, Stewart Gross about obtaining the affidavits of service from local defense counsel. 03/09/21 SEM PHASE1 Review information received from 0.20 89.00 BSA regarding the new PC-42 Doe case in New Jersey and forward same to Northern New Jersey Council with an update on the request for information. 03/09/21 SEM PHASE1 Continue reviewing historical BSA 1.00 445.00 settlement data and update and revise the Ogletree BSA Historical Settlement Spreadsheet with the same. 03/09/21 SEM PHASE1 Email discussion with Arizona 0.30 133.50 defense counsel and Arizona Plaintiff's counsel Stewart Gross regarding getting the Waivers of Service for new BSA cases executed and returned. Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 31 of 107
Page 30 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount 03/09/21 SEM PHASE1 Review current status of litigation 0.30 133.50 matters and bankruptcy case, potential future of the both and Ogletree's role in the same. 03/09/21 SEM PHASE1 Internal team meeting B. Griggs and 0.30 133.50 K. Murray to discuss overall status and recent developments. 03/09/21 KJM PHASE1 Email to S. Manning and C. Tuffey 0.20 30.00 regarding AZ and NY tracking charts. 03/09/21 KJM PHASE1 Teleconference with S. Manning, E. 0.30 45.00 Rosenberg, and M. Andolina regarding PI stipulation schedules. 03/09/21 KJM PHASE1 Review email from J.Nichols 0.10 15.00 regarding BSA internal file for Tom Parrucci. 03/09/21 KJM PHASE1 Review email received from Anna 0.10 15.00 Kutz regarding new Complaint filed in NJ. 03/09/21 KJM PHASE1 Review email received from Ashley 0.10 15.00 Halvorson regarding BSA extending stay of cases. 03/09/21 KJM PHASE1 Enter new claim into Riskonnect for 1.00 150.00 lawsuit filed by PC-42 Doe in New Jersey. 03/09/21 KJM PHASE1 Analyze lawsuit filed by PC-42 Doe 0.50 75.00 (NJ) in preparation for entering new claim into Riskonnect. 03/09/21 KJM PHASE1 Internal team meeting with Sean 0.30 45.00 Manning, Bruce Griggs and Kelci Davis to discuss overall status and recent developments. 03/10/21 BAG PHASE1 Review email update from defense 0.10 64.00 counsel in KY Explorer cases. 03/10/21 BAG PHASE1 Email to Anna Kutz regarding update 0.10 64.00 in KY Explorer cases. 03/10/21 BAG PHASE1 Review pro se Complaint in El Dey v. 0.20 128.00 Children’s Village (NY). Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 32 of 107
Page 31 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount 03/10/21 BAG PHASE1 Email exchange with Anna Kutz 0.10 64.00 regarding pro se Complaint. 03/10/21 BAG PHASE1 Email exchanges with S. Manning 0.20 128.00 regarding retention of counsel in California cases. 03/10/21 SEM PHASE1 Continue reviewing BSA historical 4.50 2,002.50 settlement data and gather same to revise and update the Ogletree BSA Historical Settlement Spreadsheet. 03/10/21 SEM PHASE1 Email discussion with BSA regarding 0.30 133.50 need to locate new California defense counsel, proposed transfer of current defense matters, and handling of pending John Roe DZ 3 case. 03/10/21 SEM PHASE1 Email exchange with current 0.20 89.00 California defense counsel regarding the filing of the Consent Order in the John Roe DZ 3 case and obtaining a copy of same. 03/10/21 SEM PHASE1 Email to Redwood Empire Council 0.10 44.50 with Notice of Consent Order filed in the John Roe DZ 3 case. 03/10/21 SEM PHASE1 Email from Illinois Plaintiff's counsel 0.10 44.50 at Hurley & McKenna regarding details of the real names of their 43 Plaintiffs in Arizona lawsuits. 03/10/21 SEM PHASE1 Telephone call with Illinois Plaintiff's 0.20 89.00 counsel at Hurley & McKenna regarding real names of their clients in Arizona and working our an agreement on acceptance of service for same. 03/10/21 SEM PHASE1 Email to Arizona defense counsel 0.20 89.00 regarding acceptance of service issues for Hurley & McKenna cases. 03/10/21 SEM PHASE1 Further email exchange with BSA 0.20 89.00 regarding details of rates CHUBB will pay for California defense counsel. 03/10/21 SEM PHASE1 Review information from BSA 0.30 133.50 bankruptcy case regarding the Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 33 of 107
Page 32 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount agreement between the parties to extend the Consent Order protection and the production of Scout unit rosters by local councils and send information about same to BSA. 03/10/21 SEM PHASE1 Review information received from 1.50 667.50 Hurley & McKenna regarding their 43 Plaintiffs in Arizona and update the Arizona Litigation Tracking Chart with the same. 03/10/21 SEM PHASE1 Email to Arizona Plaintiff Counsel 0.40 178.00 Foote and McKenna to advise they are both separately representing the same plaintiff and asking one of them to dismiss. 03/10/21 SEM PHASE1 Review report from Kentucky defense 0.20 89.00 counsel to advise that defendant Brad Schuhmann was sentenced today in the criminal case related to the LFL matters and forward same to BSA. 03/10/21 SEM PHASE1 Email from Northern New Jersey 0.10 44.50 Council indicating they have no documents or information related to the new PC-42 Doe case. 03/10/21 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 service of Process in the new Abudllah Spencer-El-Dey case in New York. 03/10/21 SEM PHASE1 Review Complaint and related 0.50 222.50 documents served on the BSA in the new Abudllah Spencer-El-Dey case in New York. 03/10/21 SEM PHASE1 Research Abudllah Spencer-El-Dey 0.40 178.00 case facts and details. 03/10/21 SEM PHASE1 Email exchange with Arizona defense 0.20 89.00 counsel regarding approval of Waiver of Service for plaintiff counsel Fasey cases. 03/10/21 SEM PHASE1 Review Waiver of Service pleading 0.10 44.50 proposed by plaintiff's counsel Fasey Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 34 of 107
Page 33 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount in Arizona. 03/10/21 SEM PHASE1 Email to Arizona plaintiff counsel 0.20 89.00 Hurley and McKenna seeking clarification of details related to John JM Doe. 03/10/21 KJM PHASE1 Enter claim in Riskonnect for multi- 0.90 135.00 plaintiff lawsuit filed by John Does 1- 65 in AZ (John Doe 2). 03/10/21 KJM PHASE1 Review email from S. Manning 0.10 15.00 regarding ShareFile folder and create link for Iesha Nunes regarding same. 03/10/21 KJM PHASE1 Review multiple email exchanges 0.20 30.00 regarding new Pro Se lawsuit filed against BSA. 03/10/21 KJM PHASE1 Review email and attachments from 0.10 15.00 Stewart Gross regarding Acceptance of Service in the Arizona cases. 03/11/21 BAG PHASE1 Telephone conference with Steve 0.30 192.00 McGowan regarding Chubb’s Opposition to Motion to extend the Temporary Injunction Order. 03/11/21 BAG PHASE1 Review Complaint in Ramnarain v. 0.50 320.00 Greater New York Council. 03/11/21 BAG PHASE1 Review Complaint in S.D. Fernancez 0.50 320.00 v. Greater New York Council. 03/11/21 BAG PHASE1 Review email and new Complaint 0.50 320.00 received from Montana defense counsel. 03/11/21 BAG PHASE1 Continue review of updated new 1.50 960.00 claims spreadsheet and review claims and cases received subsequent to 2.25. 03/11/21 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 locating additional information related to the new Federal Court pro se case filed in New York. 03/11/21 SEM PHASE1 Email exchange with White and Case 0.20 89.00 regarding request for locating and Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 35 of 107
Page 34 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount providing copies of certain Complaints. 03/11/21 SEM PHASE1 Email from Stewart Gross, Arizona 0.10 44.50 Plaintiff's attorney, with filed waivers of service in his cases. 03/11/21 SEM PHASE1 Additional email exchange with BSA 0.20 89.00 regarding the Children's Village in New York and Troop 59 there. 03/11/21 SEM PHASE1 Email to Westchester-Putnam 0.20 89.00 Council with request for information related to Children's Village and Troop 59. 03/11/21 SEM PHASE1 Collect all Hurley & McKenna cases 0.50 222.50 from Arizona with real Plaintiff names added and send same to Arizona defense counsel with details and explanations for some. 03/11/21 SEM PHASE1 Email exchange with Westchester- 0.20 89.00 Putnam Council regarding having no records for the Children's Village and probability that the Village does not either. 03/11/21 SEM PHASE1 Email discussion with White and 0.30 133.50 Case and Morris Nichols regarding potential need for obtaining a statement under oath of a dying claimant with a filed proof of claim. 03/11/21 SEM PHASE1 Begin researching Ogletree files for 0.80 356.00 specific Complaints requested by White and Case. 03/11/21 SEM PHASE1 Emails from Arizona Plaintiff's 0.20 89.00 counsel Hurley and McKenna in response to mine from yesterday about a duplicate plaintiff and errors in a Complaint for one of their clients. 03/11/21 SEM PHASE1 Email exchange with White and Case 0.20 89.00 regarding need to continue searching for BSA abuse Complaints for their proof of claim comparison project. 03/11/21 SEM PHASE1 Review Acceptance of Service 0.30 133.50 Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 36 of 107
Page 35 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount documents executed by Arizona defense counsel for Stewart Gross cases, the filed versions of the same received back from plaintiff's counsel and update the Arizona Litigation Tracking Chart with notes from the same. 03/11/21 SEM PHASE1 Review new lawsuit filed in New York 0.30 133.50 against the Greater New York Councils by Sanjev Ramnarain and collect details for the New York Litigation Tracking Chart. 03/11/21 SEM PHASE1 Review new lawsuit filed in New York 0.30 133.50 against the Greater New York Councils by S.D. Fernandez and collect details for the New York Litigation Tracking Chart. 03/11/21 SEM PHASE1 Email to BSA and Greater New York 0.20 89.00 Councils to notify about Ramnarain and Fernandez lawsuits and request a search for records from the same. 03/11/21 SEM PHASE1 Email to New York defense counsel 0.10 44.50 with notice of Ramnarain and Fernandez lawsuits and direction regarding the Fourth Notice of Consent Order. 03/11/21 SEM PHASE1 Email exchange with White and Case 0.20 89.00 regarding request for John Roe DZ 7, 8 and 9 Complaint from California. 03/11/21 SEM PHASE1 Email exchange with White and Case 0.20 89.00 and New York Defense counsel regarding an update on the BSA response in the City of Rye case and pending deadline for the same. 03/11/21 SEM PHASE1 Email exchange with Catalina Council 0.20 89.00 regarding service of process in the CR Doe, Muhs, and Boyer cases. 03/11/21 SEM PHASE1 Review service of process 0.20 89.00 documents in the CR Doe, Muhs, and Boyer cases and note the same on the Arizona Litigation Tracking Chart. Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 37 of 107
Page 36 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount 03/11/21 SEM PHASE1 Email to Arizona defense counsel to 0.20 89.00 advise of service of process on the Catalina Council in the Mahs, Boyer and CR Doe cases. 03/11/21 SEM PHASE1 Review and analyse for accuracy, the 0.40 178.00 Ogletree section of Haynes and Boone response letter to Century Insurance. 03/11/21 SEM PHASE1 Research proof of claim data from 0.20 89.00 Greater New York Councils for Ramnarain and Fernandez matters. 03/11/21 SEM PHASE1 Email exchange with Greater New 0.20 89.00 York Council regarding additional details of the Fernandez and Ramnarain cases. 03/11/21 SEM PHASE1 Email exchange with Montana 0.20 89.00 defense counsel regarding the new W.A. case filed there and BSA response to the same. 03/11/21 SEM PHASE1 Review new W.A. case in Montana 0.40 178.00 and collect details for the local council and BSA. 03/11/21 SEM PHASE1 Email to BSA and the Montana 0.20 89.00 Council to advise of the new W.A. lawsuit and provide details of the same. 03/11/21 SEM PHASE1 Email exchange with Haynes and 0.20 89.00 Boone regarding the response to Century Insurance and request for input by Ogletree. 03/11/21 SEM PHASE1 Email exchange with Arizona defense 0.20 89.00 counsel regarding remaining Plaintiff cases without known names. 03/11/21 SEM PHASE1 Email exchange with Catalina Council 0.20 89.00 regarding service of process documents in the John Does 1-26 case. 03/11/21 SEM PHASE1 Review service of process documents 0.10 44.50 in John Does 1-26 and update the Arizona Litigation Tracking Chart with Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 38 of 107
Page 37 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount information of the same. 03/11/21 SEM PHASE1 Email to Arizona defense counsel 0.10 44.50 with service of process documents in the John Does 1-26 case and input on continued attempts to get Plaintiff's real names. 03/11/21 SEM PHASE1 Additional email exchange with 0.20 89.00 Catalina Council regarding pleadings in the John Does 1-19 case received in the mail today related to the Catholic Church's Motion to Dismiss and Plaintiff's Motion to File an Amended Complaint. 03/11/21 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 additional Children's Village lawsuits and request to obtain information about the same. 03/11/21 KJM PHASE1 Review and respond to email from E. 0.10 15.00 Rosenberg regarding missing post- petition complaints. 03/11/21 KJM PHASE1 Research additional post-petation 0.20 30.00 Complaints in CA, NY and AZ and send results via email to E. Rosenberg regarding same. 03/11/21 KJM PHASE1 Email exchange with S. Manning and 0.20 30.00 D. Hirshorn regarding missing post- petition Complaints and attention to same. 03/11/21 KJM PHASE1 Review new lawsuits filed in NY, AZ 0.50 75.00 and WA. and update new claims spreadsheet regarding same. 03/11/21 KJM PHASE1 Analyze lawsuit filed by Abudllah 0.50 75.00 Spencer-El-Dey (NY) in preparation for entering new claim nto Riskonnect. 03/12/21 BAG PHASE1 Review letter from BSA to Chubb GC. 0.20 128.00 03/12/21 BAG PHASE1 Review factual sections in draft letter 0.30 192.00 from coverage counsel to Century. 03/12/21 SEM PHASE1 Email from White and Case regarding 0.10 44.50 Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 39 of 107
Page 38 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount delay in decision regarding the BSA response in the JFH matter in Missouri. 03/12/21 SEM PHASE1 Email from Plaintiff's counsel in 0.10 44.50 Arizona with finalized Acceptance of Service pleadings in the Metcalf and Gray cases. 03/12/21 SEM PHASE1 Review finalized Acceptance of 0.20 89.00 Service pleadings from Arizona Plaintiff's counsel and send approval of same to Arizona defense counsel. 03/12/21 SEM PHASE1 Update the New York Litigation 0.30 133.50 Tracking Chart with information from the new Abdullah Spencer-El-Dey case in preparation for further assignment to New York defense counsel. 03/12/21 SEM PHASE1 Email to New York defense counsel 0.20 89.00 with information related to the 22 other Children's Village lawsuits and request to obtain same. 03/12/21 SEM PHASE1 Review Plaintiff's Motion to File an 0.50 222.50 Amended Complaint and related Second Amended Complaint in the John Does 1-19 case in Arizona. 03/12/21 SEM PHASE1 Review Plaintiff's Second Amended 0.30 133.50 Complaint filed by John Does 1-19 in Arizona and collect new information to add tot he Arizona Litigation Tracking Chart. 03/12/21 SEM PHASE1 Review Plaintiff's Response to 0.40 178.00 Defendant Diocese of Tucson's Motion to Dismiss in the John Does 1-19 case in Arizona. 03/12/21 SEM PHASE1 Email to Haynes and Boone to advise 0.10 44.50 the Ogletree section of the Century Insurance response letter is approved. 03/12/21 SEM PHASE1 Email to Arizona defense counsel 0.20 89.00 with pleadings received from the Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 40 of 107
Page 39 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount Catalina Council in the John Does 1- 19 case and request to obtain the Catholic Church's Motion to Dismiss. 03/12/21 SEM PHASE1 Email to Montana Council with 0.10 44.50 information regarding the assignment of the new W.A. matter and filing of the Fourth Notice of Consent Order. 03/12/21 SEM PHASE1 Review 32 page BSA Opening Brief 0.90 400.50 in Support of Extended Preliminary Injunction Order in the adversary proceeding. 03/12/21 SEM PHASE1 Email from BSA with identification of 0.20 89.00 the alleged perpetrator in the new pro se New York lawsuit and update the New York Litigation Tracking Chart with the same. 03/12/21 SEM PHASE1 Follow-up email to Arizona plaintiffs 0.20 89.00 counsel David Lunn seeking real names of his clients. 03/12/21 SEM PHASE1 Email to White and Case regarding 0.20 89.00 the stay violation by plaintiffs' attorney David Lunn in Arizona in the John Does 1-19 case. 03/12/21 SEM PHASE1 Email exchange with New Jersey 0.20 89.00 defense counsel regarding details of response deadline in the new PC-42 Doe matter and to provide a complete copy of the Complaint. 03/12/21 SEM PHASE1 Follow-up email to Arizona plaintiffs 0.50 222.50 attorney Jason Covault to re-request the real names of his clients. 03/12/21 SEM PHASE1 Review information from Colorado 0.20 89.00 regarding the Senate committee passing a bill giving past child sex abuse survivors access to justice and update the Ogletree Pending Statutory of Limitations Litigation Memo accordingly. 03/12/21 SEM PHASE1 Email from Missouri defense counsel 0.10 44.50 with information and call-in details for Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 41 of 107
Page 40 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount pre-settlement conference call with the Court in the JFH case. 03/12/21 SEM PHASE1 Review draft status report prepared 0.10 44.50 by Illinois defense counsel for filing per court order in the Christopher Haywood case. 03/12/21 SEM PHASE1 Email exchange with Illinois defense 0.20 89.00 counsel regarding their proposed Status Report in response to the Court's Order and approval of the same. 03/12/21 SEM PHASE1 Review Arizona pleadings to gather 0.20 89.00 details for Tucson, Gallup and Phoenix Catholic Diocese attorneys to reach out to them to discuss the BSA Consent Order filing and effect on pending litigation. 03/12/21 SEM PHASE1 Email from New York defense 0.10 44.50 counsel with the first set of Children's Village Complaints. 03/12/21 SEM PHASE1 Email from Greater New York 0.10 44.50 Councils advising they have no documents or information related to the new Fernandez and Ramnarain cases. 03/12/21 SEM PHASE1 Review status of Doe v. BSA and Our 0.20 89.00 Lady of Guadalupe and email New Mexico defense counsel seeking confirmation of dismissal or reinstatement of the case. 03/12/21 SEM PHASE1 Begin reviewing Children's Village 0.90 400.50 lawsuits in New York to determine any related to the BSA and to gather alleged abuser information. 03/12/21 SEM PHASE1 Email discussion with White and 0.40 178.00 Case and counsel for Catholic Church regarding Arizona litigation matters. 03/12/21 SEM PHASE1 Email exchange with White and Case 0.30 133.50 to discuss the extensive and detailed Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 42 of 107
Page 41 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount plan of action for JFH case in Missouri. 03/12/21 SEM PHASE1 Extensive email exchange with 0.50 222.50 Missouri defense counsel and White and Case regarding additional thoughts and input on plan for BSA response in the JFH case. 03/12/21 SEM PHASE1 Review Weekly New Claims Report 0.20 89.00 to ensure all new cases have been handled. 03/12/21 KJM PHASE1 Update new claims spreadsheet with 1.50 225.00 Complaints received for the week of March 5th and send with email correspondence to BSA legal and White & Case. 03/13/21 SEM PHASE1 Email exchange with Arizona 0.20 89.00 Plaintiffs' counsel Jason Covault regarding obtaining his clients' real names, dates of abuse and working out acceptance of service issues. 03/14/21 SEM PHASE1 Review information from Colorado 0.20 89.00 regarding initial passage of Senate Bill to abolish child sexual abuse statute of limitations and update 50 state legislative watch memo for BSA. 03/14/21 SEM PHASE1 Review and revise Arizona Litigation 0.20 89.00 Tracking Chart to consolidate double entry on John Doe 1-26 case CV2020-017218. 03/14/21 SEM PHASE1 Lengthy email exchange with 0.60 267.00 Missouri defense counsel and White and Case regarding finalizing plan of response and logistics of filings in the JFH matter. 03/14/21 SEM PHASE1 Email discussion with New York 0.30 133.50 defense counsel and White and Case regarding hearing tomorrow in the City of Rye matter and handling of the case on the Consent Order Schedules. Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 43 of 107
Page 42 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount 03/14/21 SEM PHASE1 Review JFH v. BSA Settlement 0.40 178.00 Agreement from underlying case to address question by White and Case and provide input on the same. 03/14/21 SEM PHASE1 Review and provide input on the draft 0.50 222.50 emails to plaintiff's counsel, BSA and Haynes and Boone in regard to the actions being taken in the JFH matter. 03/14/21 SEM PHASE1 Email exchange with White and Case 0.30 133.50 and New York defense counsel regarding privileged strategy matters related to the City of Rye case. 03/14/21 SEM PHASE1 Email from Missouri defense counsel 0.10 44.50 with update from Traveler's Insurance regarding their plan to respond to JFH. 03/14/21 SEM PHASE1 Review revisions to the proposed 0.20 89.00 email to JFH counsel and BSA regarding the BSA response to JFH's Motion to Remand and approve of the same. 03/15/21 BAG PHASE1 Review weekly new claims report and 2.00 1,280.00 claims/cases filed subsequent to 3.5.2021. 03/15/21 BAG PHASE1 Telephone conference with S. 0.30 192.00 Manning regarding developments in and status of the Hobbs matter in K.C. 03/15/21 SEM PHASE1 Review Connecticut Yankee Council 0.20 89.00 audit response prepared by Connecticut defense counsel Wiggin and Dana. 03/15/21 SEM PHASE1 Email discussion with BSA, White 0.30 133.50 and Case and Haynes and Boone regarding JFH response status report and plan approval. 03/15/21 SEM PHASE1 Review email from White and Case to 0.10 44.50 Missouri defense counsel authorizing sending email to JFH counsel to Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 44 of 107
Page 43 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount attempt to stay Motion to Remand matter. 03/15/21 SEM PHASE1 Email from New York defense 0.10 44.50 counsel advising of City of Rye conference being adjourned until May 4, 2021. 03/15/21 SEM PHASE1 Review email exchange between 0.20 89.00 Missouri defense counsel and White and Case regarding timing of sending BSA response email to JFH counsel and checking of the docket for a JFH filing. 03/15/21 SEM PHASE1 Lengthy email to counsel for the 0.70 311.50 Diocese of Phoenix and Diocese of Tucson in Arizona regarding BSA entering Notices of Stay in their cases and plan to stop stay violation in the John Doe 1-19 case filed by David Lunn. 03/15/21 SEM PHASE1 Telephone call to counsel for the 0.30 133.50 Diocese of Gallup New Mexico to discuss BSA bankruptcy stay and Arizona John Does 1-19 lawsuit matters. 03/15/21 SEM PHASE1 Email exchange with New Mexico 0.20 89.00 defense counsel regarding status of John Doe v. BSA and Our Lady of Guadalupe case and process for it being dismissed. 03/15/21 SEM PHASE1 Email from BSA with bill tracking 0.10 44.50 service information about the Colorado child sexual abuse statute of limitation change bill update. 03/15/21 SEM PHASE1 Review Notice of Remand from 0.20 89.00 Bankruptcy Court filed in the John Doe v. Richard Lucero case in New Mexico received from local defense counsel. 03/15/21 SEM PHASE1 Email discussion with Missouri 0.40 178.00 defense counsel and White and Case regarding JFH's filing of an Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 45 of 107
Page 44 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount Opposition to Traveler's Insurance's Motion to Transfer Venue after receipt of the BSA email to request them to stand down and handling of the same. 03/15/21 SEM PHASE1 Review JFH's Suggestion in 1.00 445.00 Opposition to Traveler's Insurance's Motion to Transfer Venue and note issues for further discussion with BSA defense team. 03/15/21 SEM PHASE1 Telephone call with counsel for the 0.20 89.00 Diocese of Tucson in Arizona regarding the BSA filing Notices of Consent Orders and the stay violation of plaintiffs' counsel in John Does 1- 19. 03/15/21 SEM PHASE1 Review email from JFH counsel to 0.40 178.00 BSA local defense counsel in response to the email sent this morning and defense counsel's input on the same and respond accordingly. 03/15/21 SEM PHASE1 Email exchange with Seneca 0.20 89.00 Waterways Council regarding a new case filed in Monroe County, New York on behalf of Todd Vanliere. 03/15/21 SEM PHASE1 Telephone call with Arizona plaintiff's 0.30 133.50 counsel Jason Covault regarding collecting details of filed cases, the BSA Consent Order, service of process of the Plaintiffs' cases and related agreements for the same. 03/15/21 SEM PHASE1 Email exchange with Missouri 0.20 89.00 defense counsel regarding underlying decision in the JFH matter for denial of insurance coverage to Mackey and carry over ramifications to the bankruptcy case. 03/15/21 SEM PHASE1 Review analysis from White and 0.20 89.00 Case on JFH's counsel response to the BSA email to them this morning and respond accordingly. Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 46 of 107
Page 45 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount 03/15/21 SEM PHASE1 Email to BSA regarding activity in the 0.20 89.00 JFH matter in Missouri, need to hold underlying file materials and search for information related to coverage opinion prior to BSA settlement in underlying action. 03/15/21 SEM PHASE1 Email to White and Case regarding 0.10 44.50 need to get BSA approval prior to next steps in JFH matter. 03/15/21 SEM PHASE1 Email from Missouri defense counsel 0.10 44.50 with input on White and Case analysis of email received from JFH counsel. 03/15/21 SEM PHASE1 Extended email discussion with BSA, 0.40 178.00 White and Case and Haynes and Boone regarding coverage analysis of BSA policies for underlying Mackey settlement. 03/15/21 SEM PHASE1 Email discussion with Missouri 0.20 89.00 defense counsel and White and Case regarding production of email to JFH counsel to Traveler's counsel. 03/15/21 SEM PHASE1 Research emails from the underlying 1.00 445.00 JFH case v. BSA for emails that can assist with the analysis of the settlement agreement details. 03/15/21 SEM PHASE1 Email to White and Case and 0.50 222.50 Missouri defense counsel regarding an analysis of information discovered from research and review of emails from the underlying Hobbs v. BSA case. 03/15/21 SEM PHASE1 Email from Seneca Waterways 0.20 89.00 Council with troop rosters related to the Guy Foreman case and send same to BSA. 03/15/21 SEM PHASE1 Email from Missouri defense counsel 0.10 44.50 with link to access the pleadings from the underlying JFH v. BSA case for additional review of underlying matters leading to the JFH v. Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 47 of 107
Page 46 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount Traveler's Indemnity case. 03/15/21 SEM PHASE1 Email exchange with Grand Canyon 0.20 89.00 Council regarding service of process in the John Does 1-26 case. 03/15/21 SEM PHASE1 Email exchange with LDS Church 0.20 89.00 counsel regarding the upcoming stay extension. 03/15/21 SEM PHASE1 Email exchange with Idaho defense 0.20 89.00 counsel regarding the next Consent Order extension and status of achieving an overall bankruptcy settlement. 03/15/21 SEM PHASE1 Email from Missouri defense counsel 0.10 44.50 with input from his analysis of their emails from the underlying JFH v. BSA case. 03/16/21 BAG PHASE1 Review email from Anna Kutz 0.10 64.00 regarding New York cases. 03/16/21 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 youth protection documents reviewed for Boe, Roe, Doe case in New Jersey being returned to BSA. 03/16/21 SEM PHASE1 Email exchange with Florida defense 0.20 89.00 counsel regarding status of the bankruptcy stay for court ordered status report. 03/16/21 SEM PHASE1 Review emails recovered by Missouri 0.50 222.50 defense counsel related to the JFH v. BSA settlement. 03/16/21 SEM PHASE1 Research Ogletree files for 0.40 178.00 documents related to BSA Expert Finkelhor and provide same to BSA per their request. 03/16/21 SEM PHASE1 Conference call with Missouri 1.30 578.50 defense counsel and White and Case regarding BSA positions on JFH motions in Missouri, and strategy for responding to the same. 03/16/21 SEM PHASE1 Email to Arizona defense counsel 0.20 89.00 Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 48 of 107
Page 47 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount with service of process documents received from the Grand Canyon Council in the John Does 1-26 case and a report from the conversation with plaintiffs' counsel Jason Covault regarding collection of information and service issues in his other cases. 03/16/21 SEM PHASE1 Review new Todd Vanliere lawsuit 0.30 133.50 filed against the Seneca Waterways Council and collect details for the New York Litigation Tracking Chart. 03/16/21 SEM PHASE1 Research historical mergers between 0.10 44.50 the councils named in the new Todd Vanliere case in New York for a request for records search. 03/16/21 SEM PHASE1 Email to Seneca Waterways Council 0.10 44.50 with information obtained from the new Todd Vanliere lawsuit and request records related to the same. 03/16/21 SEM PHASE1 Email to BSA with notice of new 0.10 44.50 lawsuit against the Seneca Waterways Council. 03/16/21 SEM PHASE1 Email to New York defense counsel 0.10 44.50 to advise of new lawsuit in the Todd Vanliere matter and direct filing of the Fourth Notice of Consent Order once it becomes available. 03/16/21 SEM PHASE1 Email exchange with the Seneca 0.20 89.00 Waterways Council regarding a lack of a proof of claim for Todd Vanliere and the possible implications of same. 03/16/21 SEM PHASE1 Email exchange with Arkansas 0.20 89.00 defense counsel regarding the status of a fourth extended consent order pleading. 03/16/21 SEM PHASE1 Telephone call to Arizona plaintiffs' 0.10 44.50 counsel to follow-up on real plaintiff names, dates of abuse, and stay of litigation. Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 49 of 107
Page 48 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount 03/16/21 SEM PHASE1 Research Del-Mar-Va Council claims 0.30 133.50 and cases for inclusion in the response to the council's auditor's request and report results of the same. 03/16/21 SEM PHASE1 Email from BSA regarding inability to 0.20 89.00 locate a Proof of Claim for Todd Vanliere and update the New York Litigation Tracking Chart with the same. 03/16/21 SEM PHASE1 Email from BSA with information 0.10 44.50 related to the Fernandez case and update the New York Litigation Tracking Chart accordingly. 03/16/21 SEM PHASE1 Email from BSA with information 0.10 44.50 related to the Ramnarain case and update the New York Litigation Tracking Chart accordingly. 03/16/21 SEM PHASE1 Email exchange with New York 0.20 89.00 defense counsel regarding the Show Cause hearing in JA-011 Doe case for Plaintiff to continue using a pseudonym and the BSA response to the same. 03/16/21 SEM PHASE1 Email from Seneca Waterways 0.20 89.00 Council with troop rosters in the Todd Vanliere case and forward same to BSA. 03/16/21 SEM PHASE1 Update and revise New York 0.10 44.50 Litigation Tracking Chart to include information received from Seneca Waterways Council. 03/16/21 SEM PHASE1 Conference call with Missouri 0.60 267.00 defense counsel, White and Case, and counsel for Traveler's Insurance regarding briefing, stay of litigation and next steps in the JFH matter. 03/16/21 SEM PHASE1 Email exchange with Missouri 0.20 89.00 defense counsel and White and Case regarding JFH potential for recovery in BSA bankruptcy without a proof of Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 50 of 107
Page 49 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount claim on file. 03/16/21 SEM PHASE1 Email to White and Case regarding 0.20 89.00 request for information on the extension of the stay of litigation and late filed proofs of claims. 03/16/21 SEM PHASE1 Email to California defense counsel 0.10 44.50 advising BSA cannot agree to new rates during the bankruptcy and offering to continue the retainer under the old fee structure. 03/16/21 SEM PHASE1 Research all Connecticut claims and 0.40 178.00 cases to ensure all matters were covered by Connecticut defense counsel in their response to the council audit request. 03/16/21 SEM PHASE1 Provide a review of Connecticut 0.20 89.00 cases and claims research for follow- up audit of Connecticut Yankee Council. 03/16/21 SEM PHASE1 Extensive email discussion with BSA 0.50 222.50 and White and Case regarding the Todd Vanliere case, effect of plaintiff's failure to file a proof of claim and potential for further litigation against the Seneca Waterways Council post bankruptcy resolution. 03/16/21 SEM PHASE1 Email from Georgia defense counsel 0.10 44.50 with court order from non-BSA case in Hall County that affects BSA cases filed in the same county. 03/16/21 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 Georgia court order and potential to dismiss the pending BSA cases there. 03/16/21 SEM PHASE1 Research pending BSA cases in Hall 0.20 89.00 County Georgia and provide information related to the same to BSA. 03/16/21 SEM PHASE1 Email exchange with Las Vegas Area 0.20 89.00 Council regarding Amended Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 51 of 107
Page 50 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount Complaint pleadings received in John Does 1-29 case in Arizona. 03/16/21 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 Amended Complaint pleadings filed in the John Does 1-29 case in Arizona in violation of the stay of litigation. 03/16/21 SEM PHASE1 Email from Missouri defense counsel 0.10 44.50 following up on plan of BSA position in light of JFH's counsel agreeing to adjourn briefing on all issues to address bankruptcy stay. 03/16/21 SEM PHASE1 Review Court Order from Northern 0.20 89.00 District Federal Court of Georgia that has dismissal effect on pending BSA cases in Hall County. 03/16/21 SEM PHASE1 Review Consent Motion to Extension 0.10 44.50 of Time for Travelers to Respond to Plaintiff's Motion for Abstention and Remand filed in the JFH case today by Traveler's Indemnity Company. 03/17/21 SEM PHASE1 Email exchange with White and Case 0.20 89.00 regarding receipt of new lawsuit from Mitchell Garabedian for Brian O'Connell in Massachusetts. 03/17/21 SEM PHASE1 Research history of merged 0.10 44.50 Massachusetts councils for determination of history of new O'Connell case filed there. 03/17/21 SEM PHASE1 Review new Complaint received for 0.30 133.50 Brian O'Connell in Massachusetts and collect details for a request for records from the Spirit of Adventure Council. . 03/17/21 SEM PHASE1 Email to Spirit of Adventure Council 0.40 178.00 with a copy of the Brian O'Connell Complaint and request for information related to the same. 03/17/21 SEM PHASE1 Email to Massachusetts defense 0.20 89.00 counsel with new Brian O'Connell lawsuit and information regarding the Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 52 of 107
Page 51 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount Fourth Notice of Consent Order. 03/17/21 SEM PHASE1 Email to Arizona defense counsel to 0.30 133.50 discuss David Lunn stay violation issue. 03/17/21 SEM PHASE1 Email to Arizona plaintiffs counsel 0.20 89.00 David Lunn regarding needing to discuss withdraw of his March 8, 2021 pleadings as they violate the stay of Litigation. 03/17/21 SEM PHASE1 Telephone call with White and Case 0.10 44.50 regarding update on extended stay of litigation and forthcoming order on the same. 03/17/21 SEM PHASE1 Review Colorado Senate Bill 0.20 89.00 Amended to expand the child sexual abuse statute of limitations and update the Ogletree pending state legislation memorandum accordingly. 03/17/21 SEM PHASE1 Continue researching data from BSA 2.00 890.00 regarding historical settlements and incorporate usable data into the Ogletree BSA Historical Settlement Spreadsheet. 03/17/21 SEM PHASE1 Telephone conference with Missouri 0.40 178.00 defense counsel and White and Case regarding topic of discussion with JFH counsel and procedure for potentially continuing the stay of litigation. 03/17/21 SEM PHASE1 Conference call with Arizona 0.30 133.50 plaintiff's counsel regarding the stay of litigation, obtaining real plaintiff names and entering a confidentiality agreement for the same. 03/17/21 SEM PHASE1 Email to Arizona defense counsel 0.10 44.50 advising of conversation with plaintiff's counsel David Lunn. 03/17/21 SEM PHASE1 Review status report related to JFH 0.20 89.00 case in Missouri sent to BSA and BSA insurance coverage counsel with Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 53 of 107
Page 52 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount updated plan of action. 03/17/21 SEM PHASE1 Email exchange with Crossroads of 0.20 89.00 the West Council regarding service of process in the John Does 1-26 case. 03/17/21 SEM PHASE1 Email exchange with White and Case 0.20 89.00 regarding proposed email to sent to JFH counsel. 03/17/21 SEM PHASE1 Email from BSA with notice of 0.10 44.50 documentary airing this week on the Discovery Channel called “The Clown and the Candyman” and its coverage of the BSA abuse issues. 03/17/21 SEM PHASE1 Email from White and Case advising 0.10 44.50 Missouri defense counsel approval to send the drafted email response to JFH counsel. 03/17/21 SEM PHASE1 Email exchange with White and Case 0.20 89.00 regarding timing and inclusion of BSA in certain planning and decision making. 03/17/21 SEM PHASE1 Extensive email discussion with BSA, 0.40 178.00 White and Case and Haynes and Boone regarding the status of the JFH matter in Missouri and ongoing plan of action related to the same. 03/18/21 BAG PHASE1 Review order approving the fourth 0.10 64.00 extension o f the consent order. 03/18/21 BAG PHASE1 Exchange email with Steve McGowan 0.10 64.00 regarding extension of the consent order. 03/18/21 SEM PHASE1 Review multiple reports from 0.40 178.00 yesterday's BSA bankruptcy hearing and summarize same for client review. 03/18/21 SEM PHASE1 Email to BSA with summaries or 0.10 44.50 reports from yesterday's bankruptcy hearing. 03/18/21 SEM PHASE1 Email exchange with Washington 0.20 89.00 defense counsel regarding Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 54 of 107
Page 53 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount information regarding the extended Consent Order for his response to the court ordered status report on the same. 03/18/21 SEM PHASE1 Review service of process documents 0.20 89.00 received from the Crossroads of the West Council and update the Arizona Litigation Tracking Chart accordingly. 03/18/21 SEM PHASE1 Email to Arizona defense counsel and 0.10 44.50 BSA to advise of service of process on the Crossroads of the West Council in the John Does 1-26 case. 03/18/21 SEM PHASE1 Review 10 new lawsuits filed in New 3.20 1,424.00 York, collect information from said Complaints and update the New York Litigation Tracking Chart with the same. 03/18/21 SEM PHASE1 Conference call with National 0.50 222.50 Catholic Church counsel to discuss chartered organization status, stay of litigation, service of process issues and Consent Order matters. 03/18/21 SEM PHASE1 Email to Catholic Church National 0.10 44.50 Counsel with Consent Order and Order of Fourth Extension of the same. 03/18/21 SEM PHASE1 Email from BSA with information 0.20 89.00 related to new Brian O'Connell and related abuse claims against perpetrator Eugene Tinory and forward same to Spirit of Adventure Council. 03/18/21 SEM PHASE1 Email exchange with Idaho defense 0.20 89.00 counsel regarding entry of Order in bankruptcy court extending the Consent Order a fourth time and pending entry of a new Notice of same. 03/18/21 SEM PHASE1 Email exchange with BSA with a copy 0.20 89.00 of the Order Granting the Fourth Extension of the Consent Order and Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 55 of 107
Page 54 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount discussion of the same. 03/18/21 SEM PHASE1 Email from BSA to the Greater New 0.10 44.50 York Councils with additional information that may assist in searching for records related to the new Belle matter. 03/18/21 SEM PHASE1 Email exchange with Oregon defense 0.20 89.00 counsel regarding the status of the Fourth Extension of the Consent Order and a forthcoming template for filing Notices in their cases. 03/18/21 SEM PHASE1 Review Order approving Fourth 0.50 222.50 Stipulation of Consent Order and stay of litigation. 03/18/21 SEM PHASE1 Email from Missouri defense counsel 0.10 44.50 confirming the email to JFH counsel was sent. 03/18/21 SEM PHASE1 Email exchange with Arizona defense 0.20 89.00 counsel regarding the entry of order in the bankruptcy case extending the Consent Order stay a fourth time and getting a template sent for filing in all pending litigation. 03/18/21 SEM PHASE1 Email exchange with New Jersey 0.20 89.00 defense counsel regarding the entry of order in the bankruptcy case extending the Consent Order stay a fourth time and getting a template sent for filing in all pending litigation. 03/18/21 SEM PHASE1 Review additional information related 0.20 89.00 to the Fernandez and Ramnarain cases from the Greater New York Councils and update the New York Litigation Tracking Chart with the same. 03/18/21 SEM PHASE1 Email from BSA with names of 0.20 89.00 claimants alleging abuse at the Children's Village in New York and forward same to New York defense counsel. Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 56 of 107
Page 55 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount 03/18/21 SEM PHASE1 Email exchange with plaintiffs' 0.30 133.50 counsel in Arizona for ET Doe and LK Doe regarding acceptance of service for their clients. 03/18/21 SEM PHASE1 Email from Hurley and McKenna with 0.20 89.00 corrected information for John J.M. Doe in Arizona and revise Arizona Litigation Tracking Chart with the same. 03/18/21 SEM PHASE1 Review proposed Waiver of Service 0.10 44.50 for John ET Doe and John LK Doe in Arizona. 03/18/21 SEM PHASE1 Email to Arizona defense counsel 0.10 44.50 with draft Waivers of Service in the John ET Doe and John LK Doe and information for handling the same. 03/18/21 SEM PHASE1 Email exchange with Connecticut 0.20 89.00 defense counsel regarding a response to BSA insurer for litigation status of the Jane Doe case pending there. 03/18/21 SEM PHASE1 Email discussion with Missouri 0.30 133.50 defense counsel and White and Case regarding JFH counsel's response to our email refuting his positions on the inapplicability of the BSA bankruptcy stay and plaintiff counsel's request for a conference call tomorrow. 03/18/21 KJM PHASE1 Analyze/review new NY lawsuit 1.00 150.00 received (Sanjev Ramnarain) in preparation for entering new claim into Riskonnect. 03/18/21 KJM PHASE1 Enter new NY claim in Riskonnect for 0.50 75.00 lawsuit filed by (S. Ramnarain). 03/18/21 KJM PHASE1 Enter new NY claim in Riskonnect for 0.50 75.00 lawsuit filed by S.D. Fernandez. 03/18/21 KJM PHASE1 Analyze new NY lawsuit filed by S.D. 1.00 150.00 Fernandez in preparation for entering new claim into Riskonnect. 03/19/21 BAG PHASE1 Review email exchanges with Eric 0.20 128.00 Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 57 of 107
Page 56 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount Moats regarding update to schedule of cases. 03/19/21 SEM PHASE1 Email exchange with Morris Nichols 0.20 89.00 regarding request from BSA Creditor for correction to case number in Schedule 1 of the Consent Order. 03/19/21 SEM PHASE1 Review Consent Order Schedule 1 to 0.20 89.00 make correction requested by BSA creditor and email Morris Nichols to advise there is no error to correct. 03/19/21 SEM PHASE1 Research Arizona Complaints to 0.10 44.50 confirm case number of apparent erroneously reported case on the Consent Order Schedule 1. 03/19/21 SEM PHASE1 Gather Complaints and case details 1.00 445.00 form the New York Litigation Tracking Chart and send emails with the same to the local councils with newly filed lawsuits with requests for documents. 03/19/21 SEM PHASE1 Email from Arizona plaintiff's counsel 0.20 89.00 regarding information about the dismissal of one of the John A.H. Doe cases that was a duplicate filing. 03/19/21 SEM PHASE1 Email to White and Case seeking an 0.10 44.50 update on the Fourth Notice of Extended Consent Order template for sending to outside defense counsel. 03/19/21 SEM PHASE1 Update and revise the Fourth Notice 1.10 489.50 of Consent Order Schedules to include al new cases received over the last two weeks. 03/19/21 SEM PHASE1 Email exchange with primary Missouri 0.20 89.00 defense counsel regarding the need to file a Fourth Notice of Consent Order Extension pleading today. 03/19/21 SEM PHASE1 Email exchange with Grand Canyon 0.20 89.00 Council regarding service of process of 24 new lawsuits today. 03/19/21 SEM PHASE1 Email from BSA with information 0.10 44.50 regarding the new Crossroads of the Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 58 of 107
Page 57 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount West lawsuit and potentially related claims. 03/19/21 SEM PHASE1 Review service of process documents 0.90 400.50 in 24 cases served on the Grand Canyon Council today and update the Arizona Litigation Tracking Chart with notations of the same. 03/19/21 SEM PHASE1 Email to Crossroads of the West 0.10 44.50 Council with request for specific troop rosters from BSA Membership Standards. 03/19/21 SEM PHASE1 Email with Missouri defense counsel 0.20 89.00 regarding alternate plan for filing notice of the extended Consent Order stay in case White and Case does not get the Fourth Notice Template out today. 03/19/21 SEM PHASE1 Email exchange with White and Case 0.20 89.00 regarding need to get Fourth Notice of Consent Order on file today in some pending matters and to obtain the template for the same. 03/19/21 SEM PHASE1 Email to Missouri defense counsel 0.10 44.50 with Fourth Notice of Consent Order for filing in their cases. 03/19/21 SEM PHASE1 Email to Washington defense counsel 0.10 44.50 with Fourth Notice of Consent Order for filing in their cases. 03/19/21 SEM PHASE1 Email to New York defense counsel 0.10 44.50 with Fourth Notice of Consent Order for filing in their cases with special directions for certain cases. 03/19/21 SEM PHASE1 Email to second New York defense 0.10 44.50 counsel with Fourth Notice of Consent Order for filing in their cases with special directions on filing same for M.R. case. 03/19/21 SEM PHASE1 Email discussion with Missouri 0.30 133.50 defense counsel and White and Case to discuss JFH's response to today's Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 59 of 107
Page 58 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount phone call and agreement to work on continuation of stay of litigation. 03/19/21 SEM PHASE1 Review Stipulation for Stay of 0.10 44.50 Litigation to be entered in the JFH case between Traveler's, Liberty and Plaintiff. 03/19/21 SEM PHASE1 Email discussion with Missouri 0.30 133.50 defense counsel, White and Case and mediator in the JFH case regarding permission for counsel from White and Case to attend the mediation conference on Monday. 03/19/21 SEM PHASE1 Email exchange with Greater Hudson 0.20 89.00 Valley Council with details of the council merger with the Westchester- Putnam Council. 03/19/21 SEM PHASE1 Email to Greater Hudson Valley 0.10 44.50 Council forwarding email sent this morning to prior Scout Executive for the Hudson Valley Council. 03/19/21 SEM PHASE1 Email exchange with Crossroads of 0.20 89.00 the West Council regarding service of process today in 21 lawsuits and documents being sent when possible. 03/19/21 SEM PHASE1 Email discussion with BSA and 0.30 133.50 Connecticut Yankee Council regarding additional information related to the new Russell Greenberg case and request for further investigation by the council. 03/19/21 SEM PHASE1 Email from BSA to Great American 0.10 44.50 Council seeking additional records and information regarding an abuse matter there. 03/19/21 SEM PHASE1 Email from Washington defense 0.10 44.50 counsel with Fourth Notices filed in their cases. 03/19/21 SEM PHASE1 Email discussion with secondary 0.30 133.50 Missouri defense counsel and White and Case regarding timing of the Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 60 of 107
Page 59 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount filing of Fourth Notice of Consent Order and direction not to file in the J.F.H. case. 03/19/21 SEM PHASE1 Review Weekly New Claims Report 0.10 44.50 to ensure all new cases received this week have been handled. 03/19/21 KJM PHASE1 Begin draft of new claims report. 1.50 225.00 03/19/21 KJM PHASE1 Finalize new claims report. 1.80 270.00 03/19/21 KJM PHASE1 Prepare email communication to all 0.90 135.00 defense counsel regarding Fourth Notice of Consent Order and send to email to all defense counsel regarding same. 03/19/21 KJM PHASE1 Create ShareFile folder and send 0.20 30.00 email with link to Ashlely Halvorson regarding Grand Canyon Service of Process. 03/19/21 KJM PHASE1 Review and respond to email from S. 0.10 15.00 Manning regarding Notice of Entry of Fourth Stipulation and Order and attention to same. 03/20/21 SEM PHASE1 Extended email discussion with White 0.40 178.00 and case regarding alleged settlements with Douglas Kennedy and John Humphries. 03/20/21 SEM PHASE1 Research Ogletree and BSA 0.20 89.00 historical settlement data for information related to John Humphries. 03/20/21 SEM PHASE1 Email exchange with Catalina Council 0.20 89.00 in Arizona regarding service of process in 21 lawsuits. 03/21/21 SEM PHASE1 Email from White and Case to BSA 0.10 44.50 and BSA coverage counsel regarding an update to the JFH status and the proposed Stipulation for Stay. 03/21/21 SEM PHASE1 Email exchange with Missouri 0.20 89.00 defense counsel and White and Case regarding approval of language to Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 61 of 107
Page 60 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount send to plaintiff's counsel in the JFH case regarding the proposed stipulation of stay. 03/22/21 BAG PHASE1 Begin review of service in filing 1.00 640.00 information received from Jeff Hotchkiss, Scout Executive for the Catalina council. 03/22/21 BAG PHASE1 Review and respond to email from 0.20 128.00 Mike Andolina regarding Douglas Kennedy claim in New York. 03/22/21 BAG PHASE1 Review new claims spreadsheet and 3.00 1,920.00 cases subsequent to 3/17/2021. 03/22/21 SEM PHASE1 Review information regarding Glacier 0.20 89.00 Bay Council selling Scout camp to provide funds to the BSA bankruptcy settlement fund and send same to BSA. 03/22/21 SEM PHASE1 Email to New Jersey defense counsel 0.10 44.50 regarding directions from BSA bankruptcy counsel in the John MM Doe case. 03/22/21 SEM PHASE1 Email to Crossroads of the West 0.10 44.50 Council regarding obtaining documents served on the council in 21 new cases. 03/22/21 SEM PHASE1 Email exchange with White and Case 0.20 89.00 regarding information to include in Notice for John MM Doe case in New Jersey. 03/22/21 SEM PHASE1 Email from BSA regarding information 0.10 44.50 related to the Westchester-Putnam and Hudson Valley Councils merger. 03/22/21 SEM PHASE1 Email from New York defense 0.10 44.50 counsel regarding Fourth Notice of Consent Order being filed in John Doe AM et al. case. 03/22/21 SEM PHASE1 Email to White and case providing 0.10 44.50 further information regarding the alleged settlement with John Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 62 of 107
Page 61 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount Humphries. 03/22/21 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 expiration of the tolling agreement and ability to close file from Rio Grande Council matter. 03/22/21 SEM PHASE1 Email from Greater Hudson Valley 0.10 44.50 Council regarding lack of access to old records to search in the John Doe 16 AH case. 03/22/21 SEM PHASE1 Email discussion with Missouri 0.30 133.50 defense counsel, White and Case and plaintiff's counsel in the JFH case regarding removal of perpetrator Mackey from the proposed stipulation of stay. 03/22/21 SEM PHASE1 Update and revise New York 0.20 89.00 Litigation Tracking Chart with information received from BSA regarding the Russell Greenberg case against the Connecticut Yankee Council. 03/22/21 SEM PHASE1 Review BSA Incident Report related 0.10 44.50 to Russell Greenberg case in New York for updating John Hiller's internal BSA file. 03/22/21 SEM PHASE1 Email from Connecticut Yankee 0.10 44.50 Council with unit rosters requested by BSA for John Hiller, perpetrator in the Russell Greenberg case. 03/22/21 SEM PHASE1 Review proposed revised Stipulation 0.10 44.50 for Stay prepared by JFH counsel. 03/22/21 SEM PHASE1 Email exchange with White and Case 0.20 89.00 and New York defense counsel regarding plan of action and talking points for Monday conference in the N.P. action. 03/22/21 SEM PHASE1 Email from Crossroads of the West 0.10 44.50 Council with information related to the 21 new cases they were served with on Friday for updating the Arizona Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 63 of 107
Page 62 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount Litigation Tracking Chart. 03/22/21 SEM PHASE1 Email exchange with Arizona defense 0.20 89.00 counsel regarding proposed change to the Fourth Notice Template. 03/22/21 SEM PHASE1 Review proposed changes to the 0.10 44.50 Fourth Notice template suggested by Arizona defense counsel. 03/22/21 SEM PHASE1 Draft emails to all New York defense 0.30 133.50 counsel to advise of new lawsuits filed against local councils they represent. 03/22/21 SEM PHASE1 Email exchange with BSA and the 0.20 89.00 Northern New Jersey Council regarding a new case, F.R., served on them today. 03/22/21 SEM PHASE1 Receive and review audit request for 0.10 44.50 the Sam Houston Council. 03/22/21 SEM PHASE1 Revise and update the Arizona 0.20 89.00 Litigation Tracking Chart with information related to the service of process in 21 cases against the Crossroads of the West Council. 03/22/21 SEM PHASE1 Email to Arizona defense counsel 0.10 44.50 with information related to the Crossroads of the West service of process in 21 multi-plaintiff lawsuits. 03/22/21 SEM PHASE1 Email exchange with counsel for the 0.20 89.00 Diocese of Gallup regarding request for copies of filed Notices of Consent Order and service of process in 22 new lawsuits. 03/22/21 SEM PHASE1 Revise and update Arizona Litigation 0.20 89.00 Tracking Chart with information related to service of process in 22 new lawsuits in the Catalina Council. 03/22/21 SEM PHASE1 Email to Arizona defense counsel 0.10 44.50 with information related to the Catalina Council service of process in 22 multi-plaintiff lawsuits. Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 64 of 107
Page 63 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount 03/22/21 SEM PHASE1 Email discussion with New York 0.30 133.50 defense counsel and White and Case regarding potential BSA insurance coverage for abuse not in Scouting. 03/22/21 SEM PHASE1 Research BSA bankruptcy proofs of 0.20 89.00 claim for Rio Grande Council claim and send information regarding the same to BSA. 03/22/21 SEM PHASE1 Email to Arizona defense counsel 0.10 44.50 with information obtained from the Diocese of Tucson attorney regarding requests for copies of the Fourth Notice filed in their cases and service on the Diocese of 22 new lawsuits on Friday. 03/22/21 SEM PHASE1 Email from Iowa defense counsel with 0.10 44.50 Fourth Notice of Consent Order pleadings filed in their cases. 03/22/21 SEM PHASE1 Email from Georgia defense counsel 0.10 44.50 advising the Fourth Notice has been filed in all of their cases. 03/22/21 SEM PHASE1 Email exchange with Las Vegas Area 0.20 89.00 Council regarding service of process in all 22 of the Jason Covault lawsuits filed in Arizona. 03/22/21 SEM PHASE1 Email exchange with New Mexico 0.20 89.00 defense counsel regarding contact by Plaintiff's counsel in regard to objection or dismissal in LDS case. 03/22/21 SEM PHASE1 Email exchange with Arizona defense 0.20 89.00 counsel about counsel for United Methodist Church contact regarding the Upshur case. 03/22/21 SEM PHASE1 Telephone call to counsel for United 0.10 44.50 Methodist Church defendant in the Arizona Upshur case to discuss the stay of litigation. 03/22/21 SEM PHASE1 Email from New York defense 0.10 44.50 counsel advising of court ordered hearing in the N.P. matter for April 21, Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 65 of 107
Page 64 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount 2021 and anticipated action at that time. 03/22/21 SEM PHASE1 Email from Minnesota defense 0.10 44.50 counsel advising they filed the new Fourth Notice in their cases. 03/22/21 SEM PHASE1 Email exchange with Grand Canyon 0.20 89.00 Council regarding service of process in the Patey case today and note same on the Arizona Litigation Tracking Chart. 03/22/21 SEM PHASE1 Email to Arizona defense counsel 0.10 44.50 advising of service of process on the Grand Canyon Council in the Patey case. 03/22/21 SEM PHASE1 Email from Georgia defense counsel 0.10 44.50 with Appellate Brief for Beech Haven Baptist Church in the BSA Alan McArthur case. 03/22/21 SEM PHASE1 Review service of process documents 0.30 133.50 received from the Las Vegas Area Council and update the Arizona Litigation Tracking Chart with information related to the same. 03/22/21 SEM PHASE1 Emails to Arizona defense counsel 0.20 89.00 with service of process documents received from the Las Vegas Area Council related to the 22 lawsuits filed by Jason Covault in Arizona. 03/22/21 SEM PHASE1 Review Complaint for F.R. filed 0.40 178.00 against the Northern New Jersey Council and collect details for sending to council and defense counsel. 03/22/21 SEM PHASE1 Email to New Jersey defense counsel 0.20 89.00 with assignment of new F.R. case and to provide details of the same. 03/22/21 SEM PHASE1 Email to BSA and Northern New 0.20 89.00 Jersey Council regarding details of new F.R. case and request for rosters and information related to the claim. 03/22/21 SEM PHASE1 Email from Pennsylvania defense 0.10 44.50 Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 66 of 107
Page 65 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount counsel with new pro se inmate Complaint and docket sheet for Justin M. Spece. 03/22/21 SEM PHASE1 Review docket sheet and Complaint 0.20 89.00 for pro se inmate Justin Spece and gather information to send to BSA, appropriate local council and defense counsel. 03/22/21 SEM PHASE1 Email to Pennsylvania defense 0.20 89.00 counsel to assign new Justin Spece case and provide a Suggestion of Bankruptcy for BSA. 03/22/21 SEM PHASE1 Email to White and Case to confirm 0.10 44.50 plan for responding top new Justin Spece case in Pennsylvania with Suggestion of Bankruptcy similar to one filed in the JFH case in Missouri. 03/22/21 SEM PHASE1 Review information received from 0.10 44.50 BSA related to the John Doe 16 AH case in New York and update the New York Litigation Tracking Chart with the same. 03/22/21 SEM PHASE1 Email from BSA with information 0.10 44.50 related to the new Herbert Cocks case filed in New York and related claims naming the same perpetrator. 03/22/21 SEM PHASE1 Email from defense counsel 0.10 44.50 regarding the Fourth Notice filings in their New York and New Jersey cases. 03/22/21 SEM PHASE1 Emails from Hawaii defense counsel 0.10 44.50 with Fourth Notice filings in their cases. 03/22/21 KJM PHASE1 Review email from Bill Glahn 0.10 15.00 regarding filed Notice of Entry of Fourth Stipulation and Order (John Does, NH). 03/22/21 KJM PHASE1 Review email from Rose Field at 0.10 15.00 Grefe Sidney regarding Notice of Entry of Fourth Stipulation and Order Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 67 of 107
Page 66 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount (John Doe, IA). 03/22/21 KJM PHASE1 Review email from Ashley Halvorson 0.10 15.00 regarding edits made to Notice of Entry of Fourth Stipulation and Order . 03/22/21 KJM PHASE1 Review email from Matt Martin 0.10 15.00 regarding filed Notice of Entry of Fourth Stipulation and Order for multiple GA matters. 03/22/21 KJM PHASE1 Review email from Matt Martin 0.10 15.00 regarding additional fillings of Notice of Entry of Fourth Stipulation and Order for multiple GA matters. 03/22/21 KJM PHASE1 Review email from Bassford Remele 0.10 15.00 regarding filed Notice of Entry of Fourth Stipulation and Order (Does 382-583, MN). 03/22/21 KJM PHASE1 Review email from Hassan Popal at 0.10 15.00 Lewis Brisbois regarding filed Notice of Entry of Fourth Stipulation and Order in multiple New Jersey and New York cases. 03/22/21 KJM PHASE1 Review email from Adrian Lavarias 0.10 15.00 regarding filed Notice of Entry of Fourth Stipulation and Order (M.O., HA). 03/22/21 KJM PHASE1 Review email from Adrian Lavarias 0.10 15.00 regarding filed Notice of Entry of Fourth Stipulation and Order (John Doe 1 HA). 03/22/21 KJM PHASE1 Review email from Adrian Lavarias 0.10 15.00 regarding filed Notice of Entry of Fourth Stipulation and Order (T.A. HA). 03/22/21 KJM PHASE1 Review email from Adrian Lavarias 0.10 15.00 regarding filed Notice of Entry of Fourth Stipulation and Order (John Roe 120., HA). 03/22/21 KJM PHASE1 Review email from Matt Martin at 0.10 15.00 Dentons regarding filed Notice of Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 68 of 107
Page 67 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount Entry of Fourth Stipulation and Order in Georgia John Doe cases. 03/22/21 KJM PHASE1 Review email from Matt Martin 0.10 15.00 regarding additional fillings in Hall County regarding Notice of Entry of Fourth Stipulation and Order for multiple GA matters. 03/22/21 KJM PHASE1 Review email from Matt Martin 0.10 15.00 regarding Notice of Entry of Fourth Stipulation and Order filed in Hall County (John Doe 650 & John Doe 649). 03/23/21 BAG PHASE1 Review email and attached consent 0.50 320.00 notices received from defense counsel in New York and New Jersey. 03/23/21 BAG PHASE1 Review email and attached consent 0.30 192.00 notices from defense counsel in Hawaii. 03/23/21 BAG PHASE1 Continue review of new cases and 2.50 1,600.00 complaints received. 03/23/21 BGH PHASE1 Emails with Konrad Kircher regarding 0.20 113.00 court motion for stay. 03/23/21 BGH PHASE1 Review court order regarding 0.20 113.00 mediation. 03/23/21 BGH PHASE1 Review court docket. 0.20 113.00 03/23/21 BGH PHASE1 Telephone conference with Alex 0.20 113.00 Gardella regarding motion. 03/23/21 BGH PHASE1 Share with Alex Gardella the court's 0.10 56.50 mediation order. 03/23/21 SEM PHASE1 Email from Arizona defense counsel 0.20 89.00 with pro hac vice pleadings for Crew & Janci in the Nick Vercelli case and review the same. 03/23/21 SEM PHASE1 Email to Arizona defense counsel to 0.10 44.50 advise of need to get Fourth Notice filed in the Nick Vercelli case. Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 69 of 107
Page 68 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount 03/23/21 SEM PHASE1 Email exchange with Greater Hudson 0.20 89.00 Valley Council regarding location of records related to John Doe 16 AH case. 03/23/21 SEM PHASE1 Emails from Missouri defense 0.10 44.50 counsel from Plaintiff's counsel and mediator regarding postponement of the JFH case mediation until after the April 22, 2021 hearing and review same. 03/23/21 SEM PHASE1 Email exchange with White and 0.40 178.00 Case, Haynes and Boone, Missouri defense counsel and BSA regarding approval of plan to send email to JFH counsel this morning and revision to said email. 03/23/21 SEM PHASE1 Revise and update New York 0.10 44.50 Litigation Tracking Chart with information received from BSA related to the Herbert Cocks case. 03/23/21 SEM PHASE1 Research Pennsylvania local BSA 0.20 89.00 councils in order to search for records related to Justin Spece. 03/23/21 SEM PHASE1 Email to BSA seeking assistance in 0.10 44.50 researching pack Justin Spece claims to have been registered in at the time of his abuse. 03/23/21 SEM PHASE1 Search Master Claims Index for all 0.70 311.50 cases and claims pending against the Sam Houston Council and gather data from the same for inclusion in the Ogletree response to council audit request. 03/23/21 SEM PHASE1 Email from Washington, D.C. defense 0.10 44.50 counsel advising they have filed the Fourth Notice in their cases. 03/23/21 SEM PHASE1 Email exchange with New York 0.20 89.00 defense counsel regarding representation of defendant parties in the Priece and Mamone cases,. Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 70 of 107
Page 69 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount 03/23/21 SEM PHASE1 Review seven (7) new lawsuits filed 2.10 934.50 in New York and gather data from the same for the New York Litigation Tracking Chart. 03/23/21 SEM PHASE1 Draft information regarding the BSA 0.40 178.00 bankruptcy process and effect on AIS claims and proofs of claims for the Sam Houston Area and Del-Mar-Va Council audit responses. 03/23/21 SEM PHASE1 Email from Missouri defense counsel 0.10 44.50 regarding agreed upon email sent to JFH counsel this morning reiterating the BSA position on the stay of litigation and agreement to the stipulation of stay in the JFH case. 03/23/21 SEM PHASE1 Email from Missouri defense counsel 0.10 44.50 with filed stipulation of stay of litigation in the JFH case. 03/23/21 SEM PHASE1 Search Master Claims Index for all 0.30 133.50 cases and claims pending against the Del-Mar-Va Council and gather data from the same for inclusion in the Ogletree response to council audit request. 03/23/21 SEM PHASE1 Draft and send emails to BSA and the 0.60 267.00 affected local councils regarding the seven new lawsuits filed in New York. 03/23/21 SEM PHASE1 Email New York defense counsel to 0.20 89.00 advise of the seven (7) new lawsuits filed there and to request filing of the Fourth Notice of Consent Order in said cases. 03/23/21 SEM PHASE1 Email from Greater Hudson Valley to 0.10 44.50 advise they had a flood in 2012 and have no records prior to that time. 03/23/21 SEM PHASE1 Email from Iowa defense counsel with 0.10 44.50 Order entered by Court staying the John Doe case. 03/23/21 SEM PHASE1 Email discussion with Missouri 0.30 133.50 defense counsel and White and Case Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 71 of 107
Page 70 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount regarding the court minute entry of the "Motion" for Stay and if we should file something to clarify it was a "Stipulation" of stay. 03/23/21 SEM PHASE1 Multiple emails from Georgia defense 0.20 89.00 counsel with Fourth Notice pleadings filed in Hall County. 03/23/21 SEM PHASE1 Email exchange with counsel for First 0.20 89.00 Presbyterian Church in Arizona regarding the stay of litigation extension and filings of the Fourth Notice of Consent Order in BSA cases. 03/23/21 SEM PHASE1 Review documents received from the 0.40 178.00 Crossroads of America Council in relation to the new claim naming Joel Rhodes as the perpetrator. 03/23/21 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 need to prepare a list of local councils that lack records due to floods, fires, and other natural disasters. 03/23/21 SEM PHASE1 Email from New Mexico defense 0.10 44.50 counsel with multiple pleadings filed in the Edward Lucero v. Richard Lucero case. 03/23/21 SEM PHASE1 Telephone call with Washington 0.10 44.50 defense counsel regarding court order for a Motion to Stay one of his cases and the setting of a pre-trial conference for this Thursday. 03/23/21 SEM PHASE1 Email from the Greater New York 0.10 44.50 Councils with information related to new lawsuits. 03/23/21 SEM PHASE1 Email from Grand Canyon Council 0.20 89.00 with service of process documents in the John Does 1 and 2 case and update the Arizona Litigation Tracking Chart to note the same. 03/23/21 SEM PHASE1 Email to Arizona defense counsel to 0.10 44.50 advise of service of process on the Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 72 of 107
Page 71 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount Grand Canyon Council in the John Does 1 and 2 case. 03/23/21 SEM PHASE1 Email exchange with White and Case 0.20 89.00 and Missouri defense counsel regarding a concise breakdown of all the response deadlines for recently filed pleadings and anticipated rulings by the court. 03/23/21 SEM PHASE1 Email from BSA with an initial and 0.10 44.50 partial list of local councils that have lost records due to disasters and or mergers. 03/23/21 SEM PHASE1 Email from Washington defense 0.10 44.50 counsel to advise they were able to strike the pre-trial conference and reinstate the stay of litigation in the Rutz case. 03/23/21 KJM PHASE1 Review and respond to email from 0.10 15.00 Rose Field at Grefe Sidney regarding Notice of Entry of Fourth Stipulation and Order and attention to same. 03/23/21 KJM PHASE1 Review email from Ashley Halvorson 0.10 15.00 regarding filed Notice of Entry of Fourth Stipulation and Order in the Upshur case. 03/23/21 KJM PHASE1 Review email from Ashley Halvorson 0.10 15.00 regarding filed Notice of Entry of Fourth Stipulation and Order in the W.M. case. 03/23/21 KJM PHASE1 Review email from Ashley Halvorson 0.10 15.00 regarding filed Notice of Entry of Fourth Stipulation and Order in the Williams case. 03/23/21 KJM PHASE1 Review email from Hassan Popal at 1.00 150.00 Lewis Brisbois regarding filed Notice of Entry of Fourth Stipulation and Order in multiple New Jersey cases. 03/23/21 KJM PHASE1 Review email from Melissa Ward at 0.10 15.00 JSH Firm regarding filed Notice of Entry of Fourth Stipulation and Order Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 73 of 107
Page 72 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount in the R. Martin (AZ) case. 03/23/21 KJM PHASE1 Review email from JSH Firm 0.10 15.00 regarding filed Notice of Entry of Fourth Stipulation and Order in the Vercelli (AZ) case. 03/23/21 KJM PHASE1 Review email from JSH Firm 0.10 15.00 regarding filed Notice of Entry of Fourth Stipulation and Order in the C.J. (AZ) case. 03/23/21 KJM PHASE1 Review email from JSH Firm 0.10 15.00 regarding filed Notice of Entry of Fourth Stipulation and Order in the T.B. (AZ) case. 03/23/21 KJM PHASE1 Review email from Mellisa Ward at 0.10 15.00 JSH Firm regarding filed Notice of Entry of Fourth Stipulation and Order in the Draughon (AZ) case. 03/23/21 KJM PHASE1 Review email from Melissa Ward at 0.10 15.00 JSH Firm regarding filed Notice of Entry of Fourth Stipulation and Order in the PTAK (AZ) case. 03/24/21 BGH PHASE1 Discussions with Alex Gardella 0.30 169.50 regarding motion to stay. 03/24/21 BGH PHASE1 Review and revise notice of entry. 0.20 113.00 03/24/21 SEM PHASE1 Email exchange with Catholic Church 0.30 133.50 counsel regarding the filing of Fourth Notices of Consent Orders in their cases in Arizona. 03/24/21 SEM PHASE1 Email from New Jersey defense 0.10 44.50 counsel advising they filed the Fourth Notice in all of their cases pending in the United States District Court of New Jersey, Bankruptcy Court. 03/24/21 SEM PHASE1 Email exchange with Arizona defense 0.20 89.00 counsel regarding obtaining filed Notices of Consent Orders in their cases and continuous service of the same. 03/24/21 SEM PHASE1 Review multiple filed Fourth Notices 0.80 356.00 Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 74 of 107
Page 73 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount of Consent Order and Orders entering Stay in Arizona cases and forward same to the appropriate local BSA councils and counsel for the LDS and Catholic Church. 03/24/21 SEM PHASE1 Email exchange with LDS Church 0.20 89.00 counsel regarding the filing of the Fourth Notice of Consent Order in Idaho and New York. 03/24/21 SEM PHASE1 Further email exchange with LDS 0.20 89.00 Church counsel regarding filings in Idaho and New York. 03/24/21 SEM PHASE1 Email exchange with Idaho defense 0.20 89.00 counsel seeking an update on the Fourth Notice of Consent Order filing. 03/24/21 SEM PHASE1 Review documents received from the 0.30 133.50 Greater New York Councils related to recently filed lawsuits against their council and update the New York Litigation Tracking Chart accordingly. 03/24/21 SEM PHASE1 Draft and send emails to Minsi Trails 0.40 178.00 and Hawk Mountain Councils in search for rosters and information related to the Justin Spece case. 03/24/21 SEM PHASE1 Email exchange with White and Case 0.20 89.00 regarding the proposed Suggestion of Bankruptcy to file in the Spece case in Pennsylvania. 03/24/21 SEM PHASE1 Email from Missouri defense counsel 0.10 44.50 with court order granting the temporary stipulation of stay of litigation in the JFH case. 03/24/21 SEM PHASE1 Email exchange with Idaho defense 0.20 89.00 counsel regarding BSA billing issues. 03/24/21 SEM PHASE1 Email to BSA regarding need to work 0.10 44.50 out Idaho defense counsel billing issues. 03/24/21 SEM PHASE1 Revise the JFH Suggestion of 0.20 89.00 Bankruptcy accordingly and send to Pennsylvania defense counsel for Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 75 of 107
Page 74 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount filing in the Justin Spece case. 03/24/21 SEM PHASE1 Review 39 page Beech Haven Baptist 0.80 356.00 Church Appellate Brief in Georgia BSA McArthur case. 03/24/21 SEM PHASE1 Email from Plaintiff's counsel with 0.10 44.50 filed waivers of service in the ET and LK Doe cases in Arizona. 03/24/21 SEM PHASE1 Emails from Arizona defense counsel 0.20 89.00 with additional Notices of Fourth Consent Order filings and send same to the related local councils. 03/24/21 SEM PHASE1 Review pleadings filed in the Edward 0.50 222.50 Lucero v. Richard Lucero case related to Plaintiff's ongoing discovery complaints, separate from BSA. 03/24/21 SEM PHASE1 Email discussion with the Hawk 0.30 133.50 Mountain Council regarding the Justin Spece case and general bankruptcy matters. 03/24/21 SEM PHASE1 Review unit rosters received from 0.10 44.50 Hawk Mountain Council related to potential unit in Justin Spece case in Pennsylvania. 03/24/21 SEM PHASE1 Email exchange with Crossroads of 0.20 89.00 the West Council regarding service of process in the John Does 1-19 case and update the Arizona Litigation Tracking Chart with note of service. 03/24/21 SEM PHASE1 Email to Arizona defense counsel to 0.10 44.50 advise of service of process on the Crossroads of the West Council in the John Does 1-19 case. 03/24/21 SEM PHASE1 Draft and prepare a new chart to 0.30 133.50 track the loss of records by local BSA councils and the date of said loss. 03/24/21 SEM PHASE1 Review video discussing BSA abuse 0.40 178.00 and discussing the BSA litigation and bankruptcy and send information about same to BSA. Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 76 of 107
Page 75 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount 03/24/21 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 establishing a billing protocol and number for Idaho defense counsel. 03/24/21 SEM PHASE1 Email to Idaho defense counsel to 0.10 44.50 update regarding a new billing procedure and number forthcoming. 03/24/21 SEM PHASE1 Email from New Mexico defense 0.10 44.50 counsel with Fourth Notice filed in their John Doe case. 03/24/21 SEM PHASE1 Received and review email from New 0.10 44.50 Mexico defense counsel with Fourth Notice filed in the Edward Lucero case. 03/24/21 SEM PHASE1 Receive and review email from New 0.10 44.50 Mexico defense counsel with Fourth Notice filed in their John Doe v. Lucero case. 03/24/21 SEM PHASE1 Email from New Jersey defense 0.10 44.50 counsel with links to download Fourth Notice filings in their cases. 03/24/21 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 billing protocol for multi-plaintiff Mark Doe case in Idaho. 03/24/21 SEM PHASE1 Email from Plaintiff's counsel in 0.20 89.00 Arizona with proposed waivers of service for 16 BSA abuse lawsuits and review said waiver. 03/24/21 SEM PHASE1 Email to Arizona defense counsel 0.10 44.50 with analysis of Plaintiff's proposed waiver of service for their 16 PA cases. 03/24/21 SEM PHASE1 Email from Crossroads of the West 0.10 44.50 Council with service of process documents in the John Does 1 and 2 case. 03/24/21 AG PHASE1 Draft motion to continue stay 1.10 346.50 pursuant to bankruptcy order. 03/24/21 KJM PHASE1 Review email from Melissa Ward at 0.10 15.00 JSH Firm regarding filed Notice of Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 77 of 107
Page 76 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount Entry of Fourth Stipulation and Order in the J.P. (AZ) case. 03/25/21 BAG PHASE1 Review email and status report 0.10 64.00 received from defense counsel in (Gonzales v BSA) (FL). 03/25/21 SEM PHASE1 Email exchange with Minsi Trails 0.20 89.00 Council regarding inability to locate Justin Spece on Pack 319 rosters from the time period of his alleged abuse. 03/25/21 SEM PHASE1 Email from BSA to Idaho defense 0.10 44.50 counsel with billing protocols for mulri-plaintiff Mark Doe case. 03/25/21 SEM PHASE1 Email from Florida defense counsel 0.10 44.50 with Fourth Notice filed in the Gonzalez case. 03/25/21 SEM PHASE1 Email from Idaho defense counsel 0.20 89.00 with Fourth Notice filed in multi- plaintiff Mark Doe case and forward same to LDS counsel per their request. 03/25/21 SEM PHASE1 Review service of process documents 0.10 44.50 received from the Crossroads of the West Council and update the Arizona Litigation Tracking Chart. 03/25/21 SEM PHASE1 Email to Arizona defense counsel 0.10 44.50 with service of process documents in the John Does 1 and 2 case received from the Crossroads of the West Council. 03/25/21 SEM PHASE1 Email exchange with Golden Empire 0.20 89.00 Council regarding service of process in the John Does 1-37 case in Arizona. 03/25/21 SEM PHASE1 Review the service of process 0.10 44.50 documents received from the Golden Empire Council and update the Arizona Litigation Tracking Chart accordingly. 03/25/21 SEM PHASE1 Email to Arizona defense counsel 0.10 44.50 Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 78 of 107
Page 77 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount with service of process documents received from the Golden Empire Council in the John Does 1-37 case. 03/25/21 SEM PHASE1 Email from the Baden-Powell Council 0.10 44.50 in New York with information related to the Duda and DeLand cases filed last week. 03/25/21 SEM PHASE1 Email from Florida defense counsel 0.10 44.50 with Order entered by Court in the Gonzales case extended the stay of litigation and requiring a status report by July 26, 2021. 03/25/21 SEM PHASE1 Email exchange with Las Vegas Area 0.20 89.00 Council regarding service of process in the John Does 1 and 2 case. 03/25/21 SEM PHASE1 Review service of process documents 0.10 44.50 received from the Las Vegas Area Council in the John Does 1 and 2 case and update the Arizona Litigation Tracking Chart. 03/25/21 SEM PHASE1 Email to Arizona defense counsel 0.10 44.50 with service of process documents received from the Las Vegas Area Council in the John Does 1 and 2 case. 03/25/21 SEM PHASE1 Revise and update New York 0.10 44.50 Litigation Tracking Chart with information related to the Duda and DeLand cases received from the Baden-Powell Council. 03/25/21 SEM PHASE1 Research BSA proofs of claim for 0.20 89.00 filing related to Justin Spece. 03/25/21 SEM PHASE1 Email to White and Case about 0.10 44.50 getting access to the global BSA proofs of claim database. 03/25/21 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 search for Justin Spece in the global proofs of claim data. 03/25/21 SEM PHASE1 Email from BSA indicating they 0.10 44.50 cannot find a proof of claim for Justin Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 79 of 107
Page 78 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount Spece. 03/25/21 SEM PHASE1 Email from Idaho defense counsel 0.10 44.50 with Court order entering the stay and requiring a status report on July 19, 2021. 03/25/21 SEM PHASE1 Email from Crossroads of the West 0.20 89.00 Council with email from plaintiff's counsel attaching the proof of service of process documents in the Patey case and review the same. 03/25/21 SEM PHASE1 Email exchange with Catalina Council 0.20 89.00 regarding John Roe 1 case and service of process in the same. 03/25/21 SEM PHASE1 Review service of process documents 0.10 44.50 received by the Catalina Council in the John Roe 1 case and update the Arizona Litigation Tracking Chart with information from the council regarding the same. 03/25/21 SEM PHASE1 Email from Arizona defense counsel 0.10 44.50 with Fourth Notice filings in the William King case. 03/25/21 SEM PHASE1 Multiple emails from Arizona defense 0.20 89.00 counsel with Fourth Notices of Consent Order filed in several BSA abuse lawsuits. 03/25/21 SEM PHASE1 Email exchange with Arizona defense 0.20 89.00 counsel regarding the wording of the Waivers of Service proposed by plaintiff's counsel and approval of the same. 03/25/21 SEM PHASE1 Email from Arizona defense counsel 0.10 44.50 to plaintiff's counsel regarding agreement to execute proposed waivers of service in specific BSA abuse lawsuits. 03/25/21 SEM PHASE1 Email from Theodore Roosevelt 0.10 44.50 Council regarding Brian O'Leary case being mis-filed and proper council information. Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 80 of 107
Page 79 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount 03/25/21 SEM PHASE1 Email exchange with Arizona defense 0.30 133.50 counsel and counsel for the Diocese of Phoenix regarding pending Arizona lawsuits. 03/25/21 SEM PHASE1 Email from the Theodore Roosevelt 0.10 44.50 Council with notice of service of process in two new cases. 03/25/21 SEM PHASE1 Email from Arizona defense counsel 0.10 44.50 with several pro hac vice motions for Crew and Janci. 03/25/21 SEM PHASE1 Email from Utah defense counsel with 0.10 44.50 Fourth Notice filed in the John Doe CJ case. 03/25/21 SEM PHASE1 Email from Pennsylvania defense 0.10 44.50 counsel with BSA Suggestion of Bankruptcy and related pleadings filed in the Justin Spece case. 03/25/21 SEM PHASE1 Email exchange with Oregon defense 0.20 89.00 counsel regarding Fourth Notice of Consent Order template and order for filing in their cases. 03/25/21 SEM PHASE1 Email from Catalina Council with 0.10 44.50 service of process documents in the John Does 1 and 2 case. 03/25/21 SEM PHASE1 Review service of process documents 0.10 44.50 received from the Catalina Council and update the Arizona Litigation Tracking Chart with the same. 03/25/21 SEM PHASE1 Email to Arizona defense counsel to 0.10 44.50 advise of service of process on the Catalina Council in the John Does 1 and 2 case. 03/25/21 SEM PHASE1 Revise and update the New York 0.10 44.50 Litigation Tracking Chart with information received from the Theodore Roosevelt Council regarding the Brian O’Leary case. 03/25/21 SEM PHASE1 Email to the Suffolk County Council 0.20 89.00 with information about the Brian O’Leary case and request for Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 81 of 107
Page 80 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount documents and information. 03/25/21 SEM PHASE1 Telephone call with counsel for the 0.30 133.50 Diocese of Phoenix regarding Fourth Notices to be filed in several of their cases and the stay of litigation issue in John Does 1-19. 03/25/21 SEM PHASE1 Email exchange with Arizona defense 0.20 89.00 counsel regarding obtaining the complete updated Arizona Litigation Tracking Chart. 03/25/21 SEM PHASE1 Email to Arizona defense counsel to 0.20 89.00 advise of need to get the Fourth Notice filed in a couple of Catalina Council cases today due to the need for the Phoenix Diocese deadline to answer. 03/25/21 SEM PHASE1 Review service of process documents 0.20 89.00 received from the Theodore Roosevelt Council in the RKTRC1 case and update the New York Litigation Tracking Chart accordingly. 03/25/21 SEM PHASE1 Email to New York defense counsel 0.10 44.50 with information and documents related to the RKTRC1 case received from the Theodore Roosevelt Council. 03/25/21 SEM PHASE1 Review service of process documents 0.30 133.50 received from the Theodore Roosevelt Council in the RKTRC2 case and update the New York Litigation Tracking Chart accordingly. 03/25/21 SEM PHASE1 Email to New York defense counsel 0.10 44.50 with service of process documents in the RKTRC2 case received from the Theodore Roosevelt Council. 03/25/21 SEM PHASE1 Email to BSA with notice of new 0.10 44.50 lawsuit filed in New York against the Theodore Roosevelt Council for RKTRC2. 03/25/21 SEM PHASE1 Email to the Theodore Roosevelt 0.10 44.50 Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 82 of 107
Page 81 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount Council seeking troop rosters and other information related to the RKTRC2 case. 03/25/21 SEM PHASE1 Email from New York defense 0.10 44.50 counsel advising about court procedure related to Child Victims Act Show Cause Hearings. 03/25/21 SEM PHASE1 Email exchange with counsel for the 0.20 89.00 Diocese of Phoenix regarding the history of the stay in the John Does 1- 19 case. 03/25/21 SEM PHASE1 Review Weekly New Claims Report 0.10 44.50 to ensure all new claims have been addressed. 03/25/21 KJM PHASE1 Review email from Marilyn Pedraza 0.10 15.00 at Clarke Silverglate regarding filed Notice of Entry of Fourth Stipulation and Order (Gonzales, FL). 03/25/21 KJM PHASE1 Review email from Lynda Wolters at 0.10 15.00 Hawley Troxell regarding filed Notice of Entry of Fourth Stipulation and Order (Mark Doe 1-13, ID). 03/25/21 KJM PHASE1 Review email from Melissa Ward at 0.10 15.00 JSH Firm regarding filed Notice of Entry of Fourth Stipulation and Order in the W. King (AZ) case. 03/25/21 KJM PHASE1 Review email from Melissa Ward at 0.10 15.00 JSH Firm regarding filed Notice of Entry of Fourth Stipulation and Order in the John Doe 1-65 (AZ) case. 03/25/21 KJM PHASE1 Review email from Melissa Ward at 0.10 15.00 JSH Firm regarding filed Notice of Entry of Fourth Stipulation and Order in the John Doe 1-28 (AZ) case. 03/25/21 KJM PHASE1 Review email from Michael Skolnick 0.10 15.00 at Kipp and Christian at JSH Firm regarding filed Notice of Entry of Fourth Stipulation and Order in the John Doe C.J. (UT) case. 03/26/21 SEM PHASE1 Review information received from 0.20 89.00 Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 83 of 107
Page 82 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount Wednesday's bankruptcy hearing and summarize same for BSA. 03/26/21 SEM PHASE1 Email exchange with Pennsylvania 0.20 89.00 defense counsel regarding filing of Fourth Notices in their cases and revision to the John MM Doe Notice. 03/26/21 SEM PHASE1 Email to Arizona defense counsel 0.10 44.50 with information about the service of process on the Catalina Council in the John Roe 1 case. 03/26/21 SEM PHASE1 Email to Grand Canyon Council with 0.20 89.00 Fourth Notices of Consent Orders filed in cases pending against their council and directions for use of the same. 03/26/21 SEM PHASE1 Email to Catalina Council with Fourth 0.20 89.00 Notices of Consent Orders filed in cases pending against their council and directions for use of the same. 03/26/21 SEM PHASE1 Email to Las Vegas Area Council with 0.20 89.00 Fourth Notices of Consent Orders filed in cases pending against their council and directions for use of the same. 03/26/21 SEM PHASE1 Email to Great Southwest Council 0.10 44.50 with Fourth Notices of Consent Orders filed in cases pending against their council and directions for use of the same. 03/26/21 SEM PHASE1 Email to Crossroads of the West 0.10 44.50 Council with Fourth Notices of Consent Orders filed in cases pending against their council and directions for use of the same. 03/26/21 SEM PHASE1 Emails to multiple BSA local councils 0.50 222.50 outside of Arizona that are named in the John Does 1-28 and Jane Doe 1 case with Fourth Notices of Consent Order filed in said case in Arizona. 03/26/21 SEM PHASE1 Review additional Complaints and 0.20 89.00 Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 84 of 107
Page 83 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount filed Waivers of Service received from plaintiff's counsel Robert Pastor in Arizona lawsuits and update the Arizona Litigation tracking Chart. 03/26/21 SEM PHASE1 Email exchange with Arizona 0.20 89.00 plaintiffs' counsel regarding obtaining BSA bankruptcy proofs of claims for his clients. 03/26/21 SEM PHASE1 Email exchange with Arizona defense 0.20 89.00 counsel regarding the Fourth Notices of Consent Order filed in the John Does 1-46 and John Does 1-47 cases today. 03/26/21 SEM PHASE1 Email to Diocese of Phoenix counsel 0.10 44.50 with the Fourth Notices of Consent Order filed in the John Does 1-46 and John Does 1-47 cases today. 03/26/21 SEM PHASE1 Email from Northern New Jersey 0.10 44.50 Council with service of process documents in a new lawsuit filed for William Copeck. 03/26/21 SEM PHASE1 Review new lawsuit filed in New 0.50 222.50 Jersey for William Copeck and gather details for a request for documents and information from the Northern New Jersey Council and to send to defense counsel. 03/26/21 SEM PHASE1 Email to Northern New Jersey 0.10 44.50 Council and BSA regarding new lawsuit filed for William Copek and request for documents and information related to the same. 03/26/21 SEM PHASE1 Email to Jersey Council defense 0.10 44.50 counsel regarding new lawsuit served on the Northern New Jersey Council for William Copek and request for them to file the Fourth Notice in same. 03/26/21 SEM PHASE1 Email exchange between BSA and 0.20 89.00 White and Case confirming Idaho defense counsel is on the Ordinary Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 85 of 107
Page 84 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount Course Professional list filed with the bankruptcy court. 03/26/21 SEM PHASE1 Continue reviewing BSA historical 1.80 801.00 settlement data and gathering information for the Ogletree BSA historical settlement spreadsheet. 03/26/21 SEM PHASE1 Multiple emails from Oregon defense 0.20 89.00 counsel with filed Fourth Notices in their pending lawsuits. 03/26/21 KJM PHASE1 Prepare weekly new claims report. 3.80 570.00 03/26/21 KJM PHASE1 Review and respond to email from 0.10 15.00 Tamara Gumabon at Civille & Tang regarding filed Notice of Entry of Fourth Stipulation and Order in the J. Tudela (Guam) matter. 03/26/21 KJM PHASE1 Respond to email from J. Morgese at 0.20 30.00 Wilson Elser regarding filed Notice of Entry in numerous New Jersey matters and access via separate secure link regarding same. 03/26/21 KJM PHASE1 Review email received from John 0.20 30.00 Gray at Lewis Roca regarding pending motions filed in Does 1-19 v Catalina Council (AZ) case and Attention to same. 03/26/21 KJM PHASE1 Review email from Melissa Ward at 0.10 15.00 JSH Firm regarding filed Notice of Entry of Fourth Stipulation and Order in the John Doe 1-46 (AZ) case. 03/26/21 KJM PHASE1 Review email from Melissa Ward at 0.10 15.00 JSH Firm regarding filed Notice of Entry of Fourth Stipulation and Order in the John Doe 1-47 (AZ) case. 03/26/21 KJM PHASE1 Review and respond to email from 0.10 15.00 Sara Pomerening at Markowitz Herbold regarding filed Notice of Entry of Fourth Stipulation and Order R.A. v Oregon Trail Council case. 03/26/21 KJM PHASE1 Review email received from Joanna 0.10 15.00 Stalheim at Markowitz Herbold filed Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 86 of 107
Page 85 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount Notice of Entry of Fourth Stipulation and Order in R.R. (OR )case. 03/26/21 KJM PHASE1 Review email received from Joanna 0.10 15.00 Stalheim at Markowitz Herbold filed Notice of Entry of Fourth Stipulation and Order in R.D. (OR) case. 03/29/21 BAG PHASE1 Review March 26 open claims 1.50 960.00 spreadsheet and complaints received subsequent to March 15, 2021. 03/29/21 SEM PHASE1 Email from BSA with information 0.10 44.50 related to April 2, 2021 BSA local council briefing. 03/29/21 SEM PHASE1 Continue review of historical BSA 5.50 2,447.50 settlement data and gathering information to revise and update the Ogletree BSA Historical Settlement Spreadsheet. 03/29/21 SEM PHASE1 Email exchange with Arkansas 0.20 89.00 defense counsel regarding need for Fourth Notice template and Order to file in their cases and to provide same. 03/29/21 SEM PHASE1 Email from New Jersey defense 0.10 44.50 counsel regarding filing of Fourth Notice in the new William Copek case. 03/29/21 SEM PHASE1 Email exchange with White and Case 0.20 89.00 and New York defense counsel regarding the Fourth Notice filing in the City of Rye case and plaintiff's inquiry about the same. 03/29/21 SEM PHASE1 Email from New Hampshire defense 0.10 44.50 counsel with notice of order entering continuation of the stay of litigation in the Doe AM, et al. case. 03/29/21 SEM PHASE1 Email from Arkansas defense counsel 0.10 44.50 with Fourth Notices of Consent Order filed in their cases. 03/29/21 SEM PHASE1 Email from BSA with additional 0.10 44.50 information related to the William Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 87 of 107
Page 86 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount Copeck case in New Jersey and request to obtain additional information and documents from the Northern New Jersey Council. 03/29/21 SEM PHASE1 Email from the Seneca Waterways 0.10 44.50 Council with Complaint received in the newly filed J.P. case. 03/29/21 SEM PHASE1 Review new J.P. case filed against 0.30 133.50 the Seneca Waterways Council and collect details of the same for the New York Litigation Tracking Chart. 03/29/21 SEM PHASE1 Email to BSA with new J.P. case filed 0.20 89.00 against the Seneca Waterways Council and details of the same. 03/29/21 SEM PHASE1 Email to New York defense counsel 0.10 44.50 with Complaint in the new J.P. case against the Seneca Waterways Council and direction to file the Fourth Notice. 03/29/21 SEM PHASE1 Email to Seneca Waterways Council 0.10 44.50 to advise of notice to New York defense counsel and BSA of information received in regard to the J.P. case. 03/29/21 SEM PHASE1 Review unit rosters received from 0.10 44.50 Seneca Waterways Council related to the new J.P. case and notate the New York Litigation Tracking Chart accordingly. 03/29/21 SEM PHASE1 Email from Pennsylvania defense 0.20 89.00 counsel with orders and other pleadings in the Justin Speece case, review the same, and request for approval to waive service of summons. 03/29/21 SEM PHASE1 Email to Pennsylvania defense 0.10 44.50 counsel with approval to execute waiver of service forms for the Justin Spece case. 03/29/21 SEM PHASE1 Draft emails to Northern New Jersey 0.20 89.00 Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 88 of 107
Page 87 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount and Patriot's Path councils seeking records related to other claims naming Curtis Buttel as perpetrator. 03/29/21 SEM PHASE1 Email from Pennsylvania and New 0.10 44.50 Jersey defense counsel regarding the Fourth Notice of Consent Orders in their cases. 03/29/21 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 the request from the Golden Empire Council regarding service of process in the John Does 1-37 case filed in Arizona. 03/29/21 KJM PHASE1 Review email from attorney Bill Glahn 0.10 15.00 regarding e-filed Notice of Entry and Order in the Doe AM et al v. Boy Scouts of America et al matter in NH. 03/29/21 KJM PHASE1 Review email received from 0.10 15.00 Cheyenne Prince at Mitchell Williams regarding filed Notice of Entry of Fourth Stipulation and Order in the Stevens, Barkley, Goodrum, and Colwell Arkansas matters. 03/29/21 KJM PHASE1 Review email from Matt Smith at Saul 0.10 15.00 Ewing regarding filed Notice of Entry of Fourth Stipulation and Order in S.D. and Goener cases (PA). 03/30/21 BAG PHASE1 Review court order/opinion denying 0.30 192.00 Century Indemnity Company's appeal of bar date order. 03/30/21 SEM PHASE1 Email exchange with Seneca 0.20 89.00 Waterways Council regarding claims that mis-identified the council as the defendant entity and handling of the same. 03/30/21 SEM PHASE1 Revise and update the New York 0.10 44.50 Litigation Tracking Chart to include additional information about mis-filed cases against the Seneca Waterways Council. 03/30/21 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 89 of 107
Page 88 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount communications with Hawk Mountain Council related to chartered organization in the Justin Spece case. 03/30/21 SEM PHASE1 Review email correspondence 0.10 44.50 between BSA, Hawk Mountain Council and Regional BSA Director regarding ability to search for chartered organization information. 03/30/21 SEM PHASE1 Research information obtained 0.20 89.00 related to the Justin Spece case and send same to BSA for potential further search of chartered organization information. 03/30/21 SEM PHASE1 Review correspondence and handling 0.20 89.00 of John Does 1-37 complaint received by the Golden Empire Council and forward same to BSA in response to their request for status. 03/30/21 SEM PHASE1 Email from plaintiff's counsel for Jane 0.20 89.00 Doe in New Mexico regarding dropping plaintiff's bankruptcy proof of claim and removal of case from the BSA Consent Order. 03/30/21 SEM PHASE1 Review Consent Order Schedule 1 0.10 44.50 for information related to the New Mexico Jane Doe v. LDS Church case. 03/30/21 SEM PHASE1 Review information related to the 0.20 89.00 BSA bankruptcy court's denial of the Century Indemnity appeal related to the BSA proof of claim form and send same to BSA. 03/30/21 SEM PHASE1 Email to White and Case regarding 0.20 89.00 removal of the New Mexico Jane Doe case from the bankruptcy and Consent Order. 03/30/21 SEM PHASE1 Review 14 page bankruptcy court 0.40 178.00 Memorandum Opinion related to the Century Indemnity Company appeal of the court order allowing the bar Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 90 of 107
Page 89 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount date and claims form. 03/30/21 SEM PHASE1 Complete review of historical BSA 1.30 578.50 settlement data and updating Ogletree BSA Historical Settlement Spreadsheet with the same. 03/30/21 SEM PHASE1 Email to White and Case with 0.10 44.50 finalized Ogletree BSA Historical Settlement Spreadsheet and details of the same. 03/30/21 SEM PHASE1 Email from Northern New Jersey 0.20 89.00 Council with troop rosters and information related to the William Copeck case and review the same. 03/30/21 SEM PHASE1 Email from Northern New Jersey 0.20 89.00 Council with troop rosters and information related to the William Copeck case and review the same. 03/30/21 SEM PHASE1 Email from Northern New Jersey 0.20 89.00 Council with troop rosters and information related to the William Copeck case and review the same. 03/30/21 SEM PHASE1 Continue reviewing Arizona lawsuits 2.40 1,068.00 to collect data to search for and compare to BSA bankruptcy proofs of claim. 03/30/21 SEM PHASE1 Email from Grand Canyon Council 0.10 44.50 with service of process documents received today in the David Rausch case. 03/30/21 SEM PHASE1 Review documents served on the 0.10 44.50 Grand Canyon Council today in the David Rausch case and update the Arizona Litigation Tracking Chart accordingly. 03/30/21 SEM PHASE1 Email to Arizona defense counsel 0.10 44.50 with documents received from the Grand Canyon Council in regard to the Court Order granting Plaintiff an extension of time to serve defendants in the David Rausch case. Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 91 of 107
Page 90 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount 03/30/21 SEM PHASE1 Review Del-Mar-Va Council audit 0.20 89.00 response language and provide background on the same. 03/30/21 SEM PHASE1 Email exchange with White and Case 0.20 89.00 and New York defense counsel regarding the current status of the M.R. case and the upcoming BSA response to the same. 03/30/21 SEM PHASE1 Email exchange with Seneca 0.20 89.00 Waterways Council regarding new lawsuit filed for P.D. and details about why the case may not be legitimate. 03/30/21 SEM PHASE1 Review Complaint for P.D. filed 0.30 133.50 against the Seneca Waterways Council and collect details for the New York Litigation Tracking Chart. 03/30/21 SEM PHASE1 Review proof of claim filed in the 0.20 89.00 bankruptcy case for P.D. related to the Seneca Waterways Council. 03/30/21 SEM PHASE1 Email to BSA with information related 0.20 89.00 to the new P.D. lawsuit against the Seneca Waterways Council. 03/30/21 SEM PHASE1 Email to New York defense counsel 0.10 44.50 regarding new P.D. case filed against the Seneca Waterways Council and direction to file the Fourth Consent Order in response to the same. 03/30/21 SEM PHASE1 Additional email exchange between 0.20 89.00 White and Case and New York defense counsel regarding the M.R. case. 03/30/21 SEM PHASE1 Email from Arizona defense counsel 0.10 44.50 with Fourth Notice filed in the David Rubio case. 03/30/21 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 tracking of research related to newly filed lawsuits with questionable facts and potential dismissal issues. 03/30/21 SEM PHASE1 Email to Las Vegas Area Council with 0.10 44.50 Fourth Notice of Consent Order filed Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 92 of 107
Page 91 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount in the David Rubio case. 03/30/21 SEM PHASE1 Email to LDS Church counsel with 0.10 44.50 filed Fourth Notice in the David Rubio case. 03/30/21 SEM PHASE1 Email exchange with Las Vegas Area 0.20 89.00 Council regarding 10 notices received from the court today related to extensions of time for plaintiffs to serve complaints. 03/30/21 SEM PHASE1 Email from Arizona defense counsel 0.10 44.50 with Fourth Notice filed in the Patey case today. 03/30/21 SEM PHASE1 Email to LDS Church counsel with 0.10 44.50 Fourth Notice filed in the Patey case in Arizona. 03/30/21 SEM PHASE1 Emails to Grand Canyon and 0.10 44.50 Crossroads of the West Councils with Fourth Notice filed in the Patey case. 03/30/21 SEM PHASE1 Email from Las Vegas Area Council 0.10 44.50 with case names and numbers of 10 Orders granting Plaintiffs extended time to serve complaints today and review same. 03/30/21 SEM PHASE1 Email to Arizona defense counsel 0.10 44.50 with information related to 10 cases granted extensions for time to serve the Diocese of Phoenix today. 03/30/21 SEM PHASE1 Email to Diocese of Phoenix counsel 0.10 44.50 with a list of the 10 cases filed in Arizona where orders granting plaintiffs extended time to serve the Diocese were received in today. 03/30/21 SEM PHASE1 Email from Oregon defense counsel 0.10 44.50 with court order setting status conference in the R.R. case for August 18, 2021. 03/30/21 SEM PHASE1 Second email from Oregon defense 0.10 44.50 counsel with additional status conference order for Edward Reeder Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 93 of 107
Page 92 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount case. 03/30/21 KJM PHASE1 Email exchange with Justin Rucki 0.20 30.00 regarding Nov-Jan expense and fee detail. 03/30/21 KJM PHASE1 Email exchange with Justin Rucki 0.10 15.00 regarding Nov-Jan expense and fee detail. 03/30/21 KJM PHASE1 Work on LEDES expense and fee 1.50 225.00 detail for Nov-Jan and send to J. Rucki regarding same. 03/30/21 KJM PHASE1 Analyze lawsuit filed by Nathaniel 0.50 75.00 Pierce (NY) in preparation for entering new claim in Riskonnect. 03/30/21 KJM PHASE1 Enter new claim in Riskonnect for 1.00 150.00 lawsuit filed by Nathaniel Pierce (NY). 03/30/21 KJM PHASE1 Analyze lawsuit filed by Michael 0.20 30.00 Manome (NY) in preparation for entering new claim in Riskonnect. 03/30/21 KJM PHASE1 Analyze lawsuit filed by Michael 1.00 150.00 Manome (NY) in preparation for entering new claim in Riskonnect. 03/30/21 KJM PHASE1 Review email received from Audra 0.20 30.00 Kalinowski Wiggin and Dana regarding filed Notice of Entry of Fourth Stipulation and Order in multiple New Jersey and Connecticut cases and attention to same. 03/30/21 KJM PHASE1 Review email from Melissa Ward at 0.10 15.00 JSH Firm regarding filed Notice of Entry of Fourth Stipulation and Order in the Michael and Robert Patey (AZ) case. 03/30/21 KJM PHASE1 Review email from Melissa Ward at 0.10 15.00 JSH Firm regarding filed Notice of Entry of Fourth Stipulation and Order in the David Rubio (AZ) case. 03/31/21 SEM PHASE1 Email exchange with White and Case 0.20 89.00 regarding complaint by BSA insurer for adding Hiser v. LDS Church case Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 94 of 107
Page 93 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount to the BSA Consent ORder. 03/31/21 SEM PHASE1 Email exchange with White and Case 0.30 133.50 and Missouri defense counsel regarding lack of need to file the Fourth Notice of Consent Order in the JFH case. 03/31/21 SEM PHASE1 Email from White and Case with 0.10 44.50 information on how to remove a proof of claim from the bankruptcy case to send to plaintiff's counsel in the Jane Doe case. 03/31/21 SEM PHASE1 Review Hiser v. LDS Church proof of 0.20 89.00 claim and filing information and email White and Case with a summary of that review. 03/31/21 SEM PHASE1 Email to White and Case regarding 0.10 44.50 process of removing the Consent Order from the Jane Doe v. LDS case in New Mexico and striking the case form Schedule 1. 03/31/21 SEM PHASE1 Email to Plaintiff's counsel in the Jane 0.10 44.50 Doe v. LDS Church case in New Mexico regarding the process for removing the proof of claim from the BSA bankruptcy case. 03/31/21 SEM PHASE1 Email from Pennsylvania defense 0.10 44.50 counsel with filed Fourth Notices in their remaining cases. 03/31/21 SEM PHASE1 Multiple emails from Arizona defense 0.20 89.00 counsel with Orders entered by Court in Lewis, Upshur, Puckett, Draughon, and Vercelli cases and review the same. 03/31/21 SEM PHASE1 Emails to Grand Canyon and Las 0.20 89.00 Vegas Councils with Court Orders entered in cases pending against them granting the further stay of litigation until July 19, 2021. 03/31/21 SEM PHASE1 Email to LDS Church counsel with 0.10 44.50 Court Orders entered in cases Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 95 of 107
Page 94 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount pending against the Church in Arizona BSA cases - granting the further stay of litigation until July 19, 2021. 03/31/21 SEM PHASE1 Continue researching Arizona BSA 1.50 667.50 abuse lawsuits to compare to bankruptcy proofs of claim. 03/31/21 SEM PHASE1 Review email exchange between 0.20 89.00 Century Indemnity Company counsel and White and Case regarding continuation of Hiser case in the BSA bankruptcy stay due to proof of claim claiming a Scouting connection. 03/31/21 SEM PHASE1 Email exchange with Crossroads of 0.20 89.00 the West Council regarding receipt of Court Orders granting plaintiffs extended time to serve the Diocese of Phoenix. 03/31/21 SEM PHASE1 Telephone call from White and Case 0.20 89.00 to provide link to total proof of claim spreadsheet information and access to same. 03/31/21 SEM PHASE1 Review Arizona Litigation Tracking 2.80 1,246.00 Chart to re-run plaintiff names against the global proof of claim database for those not found on the local council spreadsheets. 03/31/21 SEM PHASE1 Email exchange with Arizona defense 0.20 89.00 counsel regarding John Does 1-19 case and an update on the status of obtaining real plaintiff names. 03/31/21 SEM PHASE1 Email discussion with White and 0.30 133.50 Case and New York defense counsel regarding direction to confer with plaintiff's counsel in the M.R. case regarding a stipulation for severance from the BSA bankruptcy case and guidance on same. 03/31/21 SEM PHASE1 Email exchange with Suffolk County 0.20 89.00 Council regarding unit roster related to the O'Leary case and to discuss Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 96 of 107
Page 95 04/26/21 Bill No. 90416189 047657.000013-BAG
Date Initials Stage Description Hours Amount request for spreadsheet tracking all cases and claims against the Council. 03/31/21 SEM PHASE1 Review information received from the 0.20 89.00 Suffolk County Council related to the O'Leary case and update the New York Litigation Tracking Chart with the same. 03/31/21 SEM PHASE1 Email exchange with Grand Canyon 0.20 89.00 Council regarding Court Orders received today extending the time for plaintiffs to serve co-defendnats in several of their lawsuits. 03/31/21 SEM PHASE1 Email from BSA with information 0.10 44.50 regarding research into adults found on troop roster in the Brian O'Leary case. 03/31/21 SEM PHASE1 Email from Arizona defense counsel 0.10 44.50 with Court Order entered in the Donald Calmes case granting the stay of litigation. 03/31/21 SEM PHASE1 Email from BSA with information 0.10 44.50 related to recently filed lawsuits and research related to the alleged perpetrators in those cases. 03/31/21 KJM PHASE1 Review emails received from Melissa 0.20 30.00 Ward at JSH Firm regarding updates to Fourth Notice of Consent Order and attention to same. 03/31/21 KJM PHASE1 Review email from Melissa Ward at 0.10 15.00 JSH Firm regarding filed-stamped Order Granting Further Stay in the Donald Calmes (AZ) case. 03/31/21 KJM PHASE1 Review email from Matt Smith at Saul 0.10 15.00 Ewing regarding file-stamped Notices in Dieterly, Barr and Powers (PA) and attention to same.
Total Services: 288.80 117,539.50 Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 97 of 107
Page 96 04/26/21 Bill No. 90416189 047657.000013-BAG
Timekeeper Summary Timekeeper Title Rate Hours Amount Bruce A. Griggs Shareholder 640.00 29.60 18,944.00 Bruce G. Hearey Shareholder 565.00 1.40 791.00 Alexandria Gardella Associate 315.00 1.10 346.50 Sean E. Manning Of Counsel 445.00 196.60 87,487.00 Kelci A. Davis Paralegal 190.00 23.90 4,541.00 Katie J. Murray Other 150.00 36.20 5,430.00
Expenses Description Amount VENDOR: Epiq eDiscovery Solutions, Inc.- AZ INVOICE#: 90521327 DATE: 3/8/2021 81.19 Epiq eDiscovery Solutions, Inc.- AZ - Monthly ediscovery storage - on 03/01/21 Total Expenses 81.19
TOTAL FEES $117,539.50 TOTAL EXPENSES $81.19 TOTAL THIS BILL $117,620.69 Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 98 of 107
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 April 26, 2021 Telephone: (864) 241-1801 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 # 90416062 Client.Matter # 083331.000000
Re: Boy Scouts of America, The - General Advice
For professional services rendered through March 31, 2021, in connection with the above-referenced matter as outlined on the attached detailed billing sheets:
Fees ...... $22,674.00 Expenses...... $0.00
Total Due This Bill...... $22,674.00
Fees Expenses Year-To-Date $85,066.05 $0.00 Life-To-Date $165,477.50 $33.22
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 4262-2 Filed 05/17/21 Page 99 of 107
Page 2 04/26/21 Bill No. 90416062 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 March 31, 2021
Date Initials Stage Description Hours Amount 03/01/21 GSM PHASE1 Make substantive revisions to 0.90 396.00 complex severance agreement as requested by Elizabeth Washka. 03/01/21 GSM PHASE1 Exchange multiple lengthy emails 0.60 264.00 with Elizabeth Washka and Lisa Young regarding issues pertaining to severance agreement. 03/01/21 GSM PHASE1 Analyze edits to proposed severance 0.60 264.00 agreement for local council employee in Ohio, as requested by Elizabeth Washka. 03/01/21 RM PHASE1 National Scouting Museum 1.20 150.00 endowment review and analysis. 03/01/21 RM PHASE1 Conference call with Jeff Hunt 1.20 150.00 regarding WR mergers. 03/01/21 RM PHASE1 Conference call with S. Phillips 1.20 150.00 regarding mergers. 03/01/21 RM PHASE1 Receipt, review and analysis of 1.20 150.00 Denver Council merger - updated bylaws. 03/01/21 RM PHASE1 National foundation loan and D.C. 1.20 150.00 UPMIFA review and analysis. 03/02/21 RM PHASE1 Review and analyze Philmont Staff 1.50 187.50 association lease matter. 03/02/21 RM PHASE1 Review and analysis of Montana 1.50 187.50 Trust Document. Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 100 of 107
Page 3 04/26/21 Bill No. 90416062 083331.000000-RWC
Date Initials Stage Description Hours Amount 03/02/21 RM PHASE1 Legal dept. reorganization research 1.50 187.50 and recommendation. 03/02/21 RM PHASE1 Review and analyze local council 1.50 187.50 assets. 03/03/21 RM PHASE1 Montana Trust document review and 3.00 375.00 analysis. 03/03/21 RM PHASE1 Local council asset review and 3.00 375.00 analysis. 03/04/21 RM PHASE1 Montana trust document review and 3.00 375.00 analysis. 03/04/21 RM PHASE1 Local council asset review and 3.00 375.00 analysis. 03/05/21 RM PHASE1 Review and analysis of Museum 1.60 200.00 Endowment documents. 03/05/21 RM PHASE1 Review and analysis of Charitable 1.70 212.50 Trust Act being implemented in HI. 03/05/21 RM PHASE1 Local council asset review and 1.70 212.50 analysis. 03/08/21 RM PHASE1 Review and analyze Glacier's Edge 1.50 187.50 trust fund documents. 03/08/21 RM PHASE1 Review and analyze local council 1.50 187.50 assets. 03/08/21 RM PHASE1 Research and analyze Museum 1.50 187.50 endowment records. 03/08/21 RM PHASE1 Respond to AD regarding same. 1.50 187.50 03/09/21 RM PHASE1 Continue researching and analyzing 6.00 750.00 local council assets. 03/10/21 RM PHASE1 Continue reviewing and analyzing 1.00 125.00 local council assets. 03/10/21 RM PHASE1 Prepare for and attend conference 1.00 125.00 call with AD on WR mergers. 03/10/21 RM PHASE1 Review and analyze FL bankruptcy 1.00 125.00 documents and respond to questions regarding same. Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 101 of 107
Page 4 04/26/21 Bill No. 90416062 083331.000000-RWC
Date Initials Stage Description Hours Amount 03/10/21 RM PHASE1 Review and analyze executive board 1.00 125.00 resources and draft memo regarding same. 03/10/21 RM PHASE1 Review and analyze Catholic Church 1.00 125.00 liability and indemnification issues. 03/10/21 RM PHASE1 Review and analyze OA endowment. 1.00 125.00 03/11/21 GSM PHASE1 Draft monthly update with status of all 0.50 220.00 pending matters. 03/11/21 RM PHASE1 Review and analyze FL Trust Council 1.20 150.00 087 documents and respond to inquiries related thereto. 03/11/21 RM PHASE1 Philtower distribution and account 1.20 150.00 document review and analysis. 03/11/21 RM PHASE1 Deed of Trust research and analysis. 1.20 150.00 03/11/21 RM PHASE1 Dissolution clause research and 1.20 150.00 analysis. 03/11/21 RM PHASE1 Continue reviewing and analyzing 1.20 150.00 executive board resources and prepare documents related thereto. 03/12/21 GSM PHASE1 Continue drafting monthly update with 0.30 132.00 status of all pending matters. 03/12/21 RM PHASE1 SLE II preparation of handouts and 2.50 312.50 materials. 03/12/21 RM PHASE1 Continue with local council asset 2.50 312.50 review. 03/15/21 RM PHASE1 Receipt and review of email 0.80 100.00 correspondence requesting updated bylaw template. 03/15/21 RM PHASE1 Brinton donation document review 0.90 112.50 and analysis. 03/15/21 RM PHASE1 Bay Lakes Trustee requirement 0.90 112.50 discussion. 03/15/21 RM PHASE1 CO merger document review and 0.80 100.00 analysis. 03/15/21 RM PHASE1 Cost center backup discussion for 0.80 100.00 Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 102 of 107
Page 5 04/26/21 Bill No. 90416062 083331.000000-RWC
Date Initials Stage Description Hours Amount PRF questions. 03/15/21 RM PHASE1 Follow up Email correspondence and 0.80 100.00 discussion regarding bylaw template revision process. 03/16/21 GSM PHASE1 Begin analyzing matters and outlining 0.90 396.00 detailed response to audit letter regarding Del-Mar-Va Council. 03/16/21 RM PHASE1 Review and analysis of NY merger 1.20 150.00 documents and court approval and bankruptcy issues related thereto. 03/16/21 RM PHASE1 SLEII prep. 1.30 162.50 03/16/21 RM PHASE1 Review and analysis of Sea Base 1.30 162.50 documentation review request. 03/16/21 RM PHASE1 Review and analysis of donor 1.20 150.00 lawsuits related to the HABs. 03/17/21 GSM PHASE1 Continue analyzing matters and 0.60 264.00 financial information and outlining response to audit letter regarding Del- Mar-Va- Council. 03/17/21 RM PHASE1 Review, analysis and discussion 1.20 150.00 regarding NY merger and bankruptcy issues. 03/17/21 RM PHASE1 SLEII prep. 1.30 162.50 03/17/21 RM PHASE1 Sea Base document review and 1.30 162.50 analysis. 03/17/21 RM PHASE1 FTSEO request and response. 1.20 150.00 03/18/21 RM PHASE1 SLE II presentation. 1.60 200.00 03/18/21 RM PHASE1 Review and analysis of the IRS Audit 1.60 200.00 403b tax rulings and research related thereto. 03/18/21 RM PHASE1 NY merger follow up on issues 1.60 200.00 regarding bankruptcy. 03/18/21 RM PHASE1 Prepare for and attend Bay Lakes 1.60 200.00 Trustee conference call. 03/18/21 RM PHASE1 Order of the Arrow fund accounting 1.60 200.00 Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 103 of 107
Page 6 04/26/21 Bill No. 90416062 083331.000000-RWC
Date Initials Stage Description Hours Amount research. 03/19/21 RM PHASE1 Sea Base document research, review 3.00 375.00 and analysis. 03/19/21 RM PHASE1 IRS 403B audit research. 3.00 375.00 03/22/21 KSH PHASE1 Extended teleconference with 1.00 460.00 Elizabeth Washka regarding gender transition issue involving Scout Executive in Boston. 03/22/21 GSM PHASE1 Begin analyzing audit letter and 0.50 220.00 relevant matters regarding Sam Houston Area Council. 03/22/21 GSM PHASE1 Analyze issues pertaining to 0.20 88.00 transgender employee and correspond with Elizabeth Washka regarding same. 03/22/21 RM PHASE1 Summer Field Foundation file review 1.50 187.50 and analysis. 03/22/21 RM PHASE1 Nation Representative Local Council 1.50 187.50 replacement search. 03/22/21 RM PHASE1 Regional HABs files review and 1.50 187.50 analysis. 03/22/21 RM PHASE1 Review mediation document. 1.50 187.50 03/23/21 GSM PHASE1 Analyze several abuse matters 0.60 264.00 regarding Sam Houston Area Council for potential inclusion in response to audit letter. 03/23/21 RM PHASE1 Central New Jersey Council 1.00 125.00 dissolution asset research, review and analysis. 03/23/21 RM PHASE1 Clarke CRT file review and 1.00 125.00 communications with CN regarding same. 03/23/21 RM PHASE1 Review and analyze Cypress Trust 1.00 125.00 lawsuit. 03/23/21 RM PHASE1 Plan, prepare for and attend Montana 1.00 125.00 Council Trust meeting. Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 104 of 107
Page 7 04/26/21 Bill No. 90416062 083331.000000-RWC
Date Initials Stage Description Hours Amount 03/23/21 RM PHASE1 Bay Lakes Council Trust review and 1.00 125.00 analysis. 03/23/21 RM PHASE1 Maui Merger review and analysis of 1.00 125.00 request from Trustee. 03/24/21 KSH PHASE1 Review Scout Executive's proposed 0.30 138.00 social media messages and other proposed internal/external communications concerning transition. 03/24/21 KSH PHASE1 Draft proposed communication for 0.50 230.00 Elizabeth Washka to send to Scout Executive in response to e-mail correspondence and proposed communications regarding upcoming transition. 03/24/21 KSH PHASE1 E-mail correspondence and 0.60 276.00 teleconference with Elizabeth Washka regarding recent communications with Scout Executive and recommendations concerning upcoming response to same. 03/24/21 GSM PHASE1 Telephone call with Elizabeth 0.30 132.00 Washka to discuss strategy for handling separation agreement offered to REDACTED . 03/24/21 GSM PHASE1 Analyze multiple emails from 0.20 88.00 Elizabeth Washka and Ken Ceaser regarding BSA equipment in the possession of REDACTED REDACTED 03/24/21 GSM PHASE1 Draft response to audit letter for Sam 0.60 264.00 Houston Area Council, and analyze status of multiple matters for inclusion in same. 03/24/21 GSM PHASE1 Draft response to audit letter for Del- 0.70 308.00 Mar-Va Council, and analyze status of multiple matters for inclusion in same. 03/24/21 RM PHASE1 Clarke CRT Split Interest Trust 1.00 125.00 Income tax filing review, analysis and communications with CN regarding Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 105 of 107
Page 8 04/26/21 Bill No. 90416062 083331.000000-RWC
Date Initials Stage Description Hours Amount same. 03/24/21 RM PHASE1 CO merger update and bylaws review 1.00 125.00 and analysis. 03/24/21 RM PHASE1 Foundation Trust review and 1.00 125.00 analysis. 03/24/21 RM PHASE1 Local council asset review and 1.00 125.00 analysis. 03/24/21 RM PHASE1 Prepare for and attend meeting with 1.00 125.00 GC regarding Greater Hudson Valley merger update. 03/24/21 RM PHASE1 Cypress Lawsuit review and 1.00 125.00 discussion with staff. 03/25/21 CEM PHASE2 Review and revise voluntary 0.30 138.00 termination policy and email to Ken Ceaser. 03/25/21 CEM PHASE2 Draft email to Ken Ceaser 0.30 138.00 summarizing state laws that prohibit "use it or lose it" PTO policies. 03/25/21 KSH PHASE1 E-mail correspondence with Elizabeth 0.30 138.00 Washka regarding Scout Executive's revised proposed communication and recommendations concerning removal of invitation for additional information. 03/25/21 GSM PHASE1 Exchange multiple emails with 0.60 264.00 Elizabeth Washka and counsel for REDACTED garding status of separation agreement and return of BSA property. 03/25/21 RM PHASE1 Foundation Trust and IRS filings 3.00 375.00 research, review and analysis. 03/25/21 RM PHASE1 Local council asset review and 3.00 375.00 analysis. 03/26/21 CEM PHASE2 Email exchange with Ken Ceaser 0.20 92.00 regarding transition questions regarding move to "use it or lose it" PTO policy. Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 106 of 107
Page 9 04/26/21 Bill No. 90416062 083331.000000-RWC
Date Initials Stage Description Hours Amount 03/26/21 CEM PHASE1 Telephone conversation with Ken 0.10 46.00 Ceaser regarding PTO compliance. 03/26/21 GSM PHASE1 Exchange multiple emails with 0.20 88.00 Elizabeth Washka and counsel for REDACTED regarding status of separation agreement and return of BSA property. 03/26/21 RM PHASE1 Local council asset review and 5.00 625.00 analysis. 03/29/21 RM PHASE1 Pooled income file review. 1.00 125.00 03/29/21 RM PHASE1 Research and respond to questions 1.00 125.00 regarding the charter org and incorporation. 03/29/21 RM PHASE1 Prepare for and attend pooled income 1.00 125.00 meeting with Cicely. 03/29/21 RM PHASE1 Prepare for and attend call with 1.00 125.00 Cicely regarding Cypress lawsuit. 03/29/21 RM PHASE1 Review and analyze Summit use 1.00 125.00 legal opinion. 03/29/21 RM PHASE1 Prepare for and attend BSA Legal 1.00 125.00 deptartment meeting. 03/30/21 GSM PHASE1 Draft detailed response to audit letter 0.80 352.00 for Del-Mar-Va Council. 03/30/21 GSM PHASE1 Analyze audit letter for Glacier's Edge 0.60 264.00 Council and begin analyzing relevant matters for potential inclusion in response. 03/30/21 RM PHASE1 Diversity training and provide 1.50 187.50 feedback. 03/30/21 RM PHASE1 Trust return income tax filing review 1.50 187.50 and analysis. 03/30/21 RM PHASE1 Review and analyze membership 1.50 187.50 provide options on structure. 03/30/21 RM PHASE1 Review and analyze documents 1.50 187.50 relating to the Summit project and prepare memo on options and Case 20-10343-LSS Doc 4262-2 Filed 05/17/21 Page 107 of 107
Page 10 04/26/21 Bill No. 90416062 083331.000000-RWC
Date Initials Stage Description Hours Amount challenges. 03/31/21 RM PHASE1 Continue review and analysis of 2.00 250.00 Summit project documents. 03/31/21 RM PHASE1 Trust return review and analysis. 2.00 250.00 03/31/21 RM PHASE1 Draft memo on options and issues. 2.00 250.00
Total Services: 147.30 22,674.00
Timekeeper Summary Timekeeper Title Rate Hours Amount Kelly S. Hughes Shareholder 460.00 2.70 1,242.00 Gavin S. Martinson Shareholder 440.00 9.70 4,268.00 Charles E. McDonald, III Shareholder 460.00 0.90 414.00 Russell C. McNamer Counsel 125.00 134.00 16,750.00
TOTAL FEES $22,674.00 TOTAL EXPENSES $0.00 TOTAL THIS BILL $22,674.00 Case 20-10343-LSS Doc 4262-3 Filed 05/17/21 Page 1 of 6
Exhibit B
Phase 2 Fees and Expense Itemization
Case 20-10343-LSS Doc 4262-3 Filed 05/17/21 Page 2 of 6
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 April 26, 2021 Telephone: (864) 241-1801 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 # 90416067 Client.Matter # 047657.000013
Re: BSA General Defense - Bankruptcy (Billiable)
For professional services rendered through March 31, 2021, in connection with the above-referenced matter as outlined on the attached detailed billing sheets:
Fees ...... $5,290.00 Expenses...... $0.00
Total Due This Bill...... $5,290.00
Fees Expenses Year-To-Date $44,120.20 $22.35 Life-To-Date $1,746,954.70 $2,332.93
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 4262-3 Filed 05/17/21 Page 3 of 6
Page 2 04/26/21 Bill No. 90416067 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)
For professional services rendered through March 31, 2021
Date Initials Stage Description Hours Amount 03/01/21 BAG PHASE2 Work on 4th interim fee application. 1.50 960.00 03/02/21 KAD PHASE2 Email exchange with Eric Moats 0.10 19.00 regarding budget form for interim fee application. 03/02/21 KAD PHASE2 Email exchange with Kirk May 0.10 19.00 regarding billing instructions and information on J.F.H. lawsuit. 03/02/21 KAD PHASE2 Email exchange with Robyn Jungers 0.10 19.00 and Anna Kutz regarding billing on Arizona lawsuits and noting same in Riskonnect. 03/02/21 KAD PHASE2 Conference call with Ashley 0.30 57.00 Halvorson and Sean Manning regarding Arizona lawsuit billing issues. 03/03/21 KJM PHASE2 Begin review and analysis of all billing 0.70 105.00 entries for inclusion of OD 12th monthly fee application. 03/03/21 KJM PHASE2 Final review and analysis of all billing 0.30 45.00 entries for inclusion of OD 12th monthly fee application email to B. Griggs regarding same. 03/04/21 BAG PHASE2 Review and respond to email from 0.20 128.00 Desiree Vale at Morris Nichols regarding 10th monthly fee application. 03/04/21 SEM PHASE2 Conference call with Robyn Jungers, 0.40 178.00 Case 20-10343-LSS Doc 4262-3 Filed 05/17/21 Page 4 of 6
Page 3 04/26/21 Bill No. 90416067 047657.000013-BAG
Date Initials Stage Description Hours Amount Anna Kutz, Lynn Richardson, Ashley Halvorson, Kelci Davis and Katie Murray regarding Arizona lawsuit billing issues. 03/04/21 KAD PHASE2 Review email from Desiree Vale 0.10 19.00 regarding CNO to Ogletree's 10th fee application. 03/04/21 KAD PHASE2 Conference call with Robyn Jungers, 0.40 76.00 Anna Kutz, Lynn Richardson, Ashley Halvorson, Sean Manning and Katie Murray regarding Arizona lawsuit billing issues. 03/04/21 KJM PHASE2 Conference call with Robyn Jungers, 0.40 60.00 Anna Kutz, Lynn Richardson, Ashley Halvorson, Kelci Davis and Sean Manning regarding Arizona lawsuit billing issues. 03/05/21 KAD PHASE2 Review email from Desiree Vale 0.10 19.00 regarding Ogletree's CNO for the 10th fee application. 03/08/21 KAD PHASE2 Email exchange with Yesmy Romero 0.10 19.00 and Robyn Jungers regarding process for handling Wiggin and Dana's invoices that pertain to Chubb matters. 03/08/21 KJM PHASE2 Email exchange with Nicole Capece 0.10 15.00 at Melick & Porter, LLP regarding insurance coverage in the Guy Forman v Seneca Waterways Council (NY) and ebilling question pertaining to same. 03/09/21 KJM PHASE2 Review and submit Epic invoice for 0.10 15.00 processing of payment. 03/10/21 BAG PHASE2 Review/redact February draft invoices 1.00 640.00 for inclusion in monthly fee application. 03/10/21 BAG PHASE2 Complete work on fourth interim fee 1.00 640.00 application. 03/10/21 KJM PHASE2 Finalize 4th Interim Fee Application 1.00 150.00 with Exhibits and email B. Griggs and Case 20-10343-LSS Doc 4262-3 Filed 05/17/21 Page 5 of 6
Page 4 04/26/21 Bill No. 90416067 047657.000013-BAG
Date Initials Stage Description Hours Amount K. Davis regarding same. 03/10/21 KJM PHASE2 Exchange email with B. Griggs 0.10 15.00 regarding 12th monthly fee application. 03/10/21 KJM PHASE2 Exchange email with B. Griggs 0.10 15.00 regarding 4th interim fee application. 03/10/21 KJM PHASE2 Email to E. Moats and P. Topper 0.10 15.00 regarding OD's 4th interim fee application. 03/10/21 KJM PHASE2 Review email received from B. Griggs 0.10 15.00 regarding 4th interim fee application. 03/10/21 KJM PHASE2 Email exchange with P. Topper 0.20 30.00 regarding 4th interim application. 03/10/21 KJM PHASE2 Prepare Exhibit C to 4th Interim Fee 0.80 120.00 Application. 03/15/21 BAG PHASE2 Review CNO to the 11th monthly fee 0.10 64.00 application received from Desiree Vale. 03/15/21 KJM PHASE2 Begin preparation of 12th monthly fee 1.50 225.00 application , materials and exhibits. 03/16/21 KJM PHASE2 Continue work on OD's 12th monthly 0.40 60.00 fee application. 03/17/21 BAG PHASE2 Work on 12th monthly fee application. 1.00 640.00 03/17/21 KJM PHASE2 Finalize 12th monthly fee application 0.20 30.00 and send to B. Griggs regarding same. 03/17/21 KJM PHASE2 Email communication to E. Moats and 0.10 15.00 P. Topper regarding OD's 12th monthly fee application. 03/26/21 BAG PHASE2 Review and respond to email from 0.20 128.00 Brendan corneal Lee at Morris, Nichols regarding fourth interim fee application. 03/29/21 KJM PHASE2 Email exchange with Kayron Headley 0.20 30.00 regarding additional information needed for handling billing and Case 20-10343-LSS Doc 4262-3 Filed 05/17/21 Page 6 of 6
Page 5 04/26/21 Bill No. 90416067 047657.000013-BAG
Date Initials Stage Description Hours Amount attention to same. 03/31/21 KJM PHASE2 Work on LEDES fee and expense 3.00 450.00 detail spreadsheet for Nov-Jan. 03/31/21 KJM PHASE2 Exchange email with J. Rucki 0.10 15.00 regarding LEDES fee and expense detail for Nov-Jan and attention to same. 03/31/21 KJM PHASE2 Prepare Ogletree's expense and fee 1.60 240.00 detail in connection with the 12th monthly fee application.
Total Services: 17.80 5,290.00
Timekeeper Summary Timekeeper Title Rate Hours Amount Bruce A. Griggs Shareholder 640.00 5.00 3,200.00 Sean E. Manning Of Counsel 445.00 0.40 178.00 Kelci A. Davis Paralegal 190.00 1.30 247.00 Katie J. Murray Other 150.00 11.10 1,665.00
TOTAL FEES $5,290.00 TOTAL EXPENSES $0.00 TOTAL THIS BILL $5,290.00 Case 20-10343-LSS Doc 4262-4 Filed 05/17/21 Page 1 of 3
Exhibit C
Category Amount Legal Support Services $81.19 Other (Immigration related) $11.24 TOTAL: $92.43
9 Case 20-10343-LSS Doc 4262-4 Filed 05/17/21 Page 2 of 3
Submit Via E-Mail Only – OGLETREE, DEAKINS, NASH, Do Not Send Hard Copy SMOAK & STEWART, P.C. Attorneys at Law Administrative Office 50 International Drive Patewood IV, Suite 200 Greenville, SC 29615 April 15, 2021 Telephone: (864) 241-1801 Facsimile: (864) 241-1908 www.ogletreedeakins.com
Kenneth Ceaser Boy Scouts of America, The - DIP 1325 West Walnut Hill Lane P.O. Box 152079 Irving, TX 75015-2079 [email protected]
PERSONAL AND CONFIDENTIAL Bill # 90403731
Re: REDACTED
For professional services rendered through March 31, 2021, in connection with the above-referenced matter as outlined on the attached detailed billing sheets:
Flat Rate Legal Fee...... $0.00 Associated Expenses ...... $11.24
Total Due This Bill...... $11.24
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 4262-4 Filed 05/17/21 Page 3 of 3
Page 2 04/15/21 Bill No. 90403731 083331.000024-LNG
Kenneth Ceaser Boy Scouts of America, The - DIP 1325 West Walnut Hill Lane P.O. Box 152079 Irving, TX 75015-2079 [email protected] Re: REDACTED
For professional services rendered through March 31, 2021
Expenses Description Amount Express Delivery/Postage 1.00 @ 11.24 ea. 11.24 Total Expenses 11.24
TOTAL FEES $0.00 TOTAL EXPENSES $11.24 TOTAL THIS BILL $11.24