Case 20-10343-LSS Doc 1392 Filed 10/01/20 Page 1 of 10
IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE
In re: Chapter 11
BOY SCOUTS OF AMERICA AND Case No. 20-10343 (LSS) DELAWARE BSA, LLC,1 (Jointly Administered)
Debtors. Obj. Deadline: October 15, 2020 at 4:00 p.m. (ET)
SUMMARY COVER SHEET OF SIXTH MONTHLY APPLICATION OF OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C. FOR ALLOWANCE OF COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR THE PERIOD FROM AUGUST 1, 2020 TO AND INCLUDING AUGUST 31, 2020
Name of Applicant: Ogletree, Deakins, Nash, Smoak & Stewart, P.C.
Authorized to Provide Professional Services to: Debtors and Debtors in Possession
Date of Retention: February 18, 2020
Period for Which Compensation and Reimbursement Are Requested: August 1, 2020 – August 31, 2020
Amount of Compensation Requested: $103,968.56 (80% of $129,960.70)2
Amount of Compensation Requested from $32,427.65 Insurers:
Amount of Expense Reimbursement Requested: $100.31
Amount of Expense Reimbursement Requested $0.00 from Insurers:
This is a(n): monthly x interim final application
1 The Debtors in these chapter 11 cases, together with the last four digits of each Debtor’s federal tax identification number, are as follows: Boy Scouts of America (6300) and Delaware BSA, LLC (4311). The Debtors’ mailing address is 1325 West Walnut Hill Lane, Irving, Texas 75038. 2 The amount of compensation and fees requested does not include fees and expenses to be paid directly to Ogletree Deakins by one or more insurance carriers in certain non-abuse claims or cases. While Ogletree Deakins reserves the right to seek future payment from the Debtors for such claims and cases, at this time Ogletree Deakins is not seeking payment from the Debtors on these claims and cases.
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PRIOR MONTHLY APPLICATIONS FILED
Requested Approved Outstanding Date Period Filed; Fees Expenses Fees Expenses Fees Expenses Covered Docket No. February 4/29/2020; 18, 2020 – Docket No. $393,030.80 $1,923.42 $314,424.64 $1,923.42 $34.20 $0 March 31, 512 2020 April 1, 5/28/2020; 2020 – Docket No. $146,042.10 $128.96 $116,833.68 $128.96 $0 $0 April 30, 717 2020 May 1, 6/18/2020; 2020 – Docket No. $128,646.50 $627.81 $102,917.20 $627.81 $102,917.20 $627.81 May 31, 867 2020 June 1, 7/22/2020; 2020 – Docket No. $133,225.40 $81.19 $106,580.32 $81.19 $106,580.32 $81.19 June 30, 1037 2020 8/21/2020; July 1, Docket No. 2020 – July $136,960.85 $81.19 $109,544.68 $81.19 $109,544.68 $81.19 1137 31, 2020
COMPENSATION AND HOURS BY PROFESSIONAL
Year of Position Admission Hourly Total Total Name Area of / Years of Rate Hours3 Compensation Expertise Experience Bruce A. Griggs Shareholder 1989 / 31 $640.00 57.8 $36,992.00 Gavin Martinson Shareholder 2005 / 15 $440.00 7.9 $3,270.60 Ronald W. Chapman Shareholder 1995 / 25 $650.00 0.2 $129.60 Sean E. Manning Of Counsel 2001 / 19 $425.00 143.3 $63,768.50 Kelci A. Davis Paralegal N/A $190.00 135 $25,650.00 Katie Murray Other N/A $150.00 1 $150.00 Total 345.2 $129,960.70
3 Ogletree, Deakins, Nash, Smoak & Stewart, P.C. charged the Debtors for 50% of non-working travel time in compliance with Local Rule 2016-2(d)(viii). Such reductions are reflected in the figures in this column.
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COMPENSATION AND EXPENSES BY PROJECT CATEGORY
Task Description Total Hours Total Compensation
Litigation/Claims / Phase 1 303.3 $118,852.70 Retention Issues / Phase 2 41.9 $11,108.00 Plan Issues / Phase 3 0 $0 Non-working Travel / Phase 4 0 $0 TOTAL 345.2 $129,960.70
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EXPENSES BY CATEGORY
Category Amount Delivery Services/Messenger $19.12 Legal Support Services $81.19 TOTAL: $100.31
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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE
In re: Chapter 11
BOY SCOUTS OF AMERICA AND Case No. 20-10343 (LSS) DELAWARE BSA, LLC,1 (Jointly Administered)
Debtors. Obj. Deadline: October 15, 2020 at 4:00 p.m. (ET)
SIXTH MONTHLY APPLICATION OF OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C. FOR ALLOWANCE OF COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR THE PERIOD FROM AUGUST 1, 2020 TO AUGUST 31, 2020
Ogletree, Deakins, Nash, Smoak & Stewart, P.C. (“Ogletree Deakins”), special litigation counsel for the Boy Scouts of America and Delaware BSA, LLC, the non-profit corporations that are debtors and debtors in possession (together, the “Debtors”) in the above-captioned chapter 11 cases, hereby submits this second monthly application (this “Application”) requesting payment in the aggregate amount of $103,968.56, which is equal to (a) 80% of the $129,960.70 of total compensation earned by Ogletree Deakins for its services to the Debtors during the period from
August 1, 2020 to and including August 31, 2020 (the “Fee Period”) and (b) 100% of the $100.31 of necessary expenses incurred by Ogletree Deakins during the Fee Period in connection with its services to the Debtors.2 In support of this Application, Ogletree Deakins respectfully represents as follows:
1The Debtors in these chapter 11 cases, together with the last four digits of each Debtor’s federal tax identification number, are as follows: Boy Scouts of America (6300) and Delaware BSA, LLC (4311). The Debtors’ mailing address is 1325 West Walnut Hill Lane, Irving, Texas 75038. 2 The amount of compensation and fees requested does not include fees and expenses to be paid directly to Ogletree Deakins by one or more insurance carriers in certain non-abuse claims or cases. While Ogletree Deakins reserves the right to seek future payment from the Debtors for such claims and cases, at this time Ogletree Deakins is not seeking payment from the Debtors on these claims and cases.
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JURISDICTION AND VENUE
1. The United States Bankruptcy Court for the District of Delaware (the “Court”) has jurisdiction over this matter pursuant to 28 U.S.C. § 1334 and the Amended Standing Order of
Reference from the United States District Court for the District of Delaware, dated February 29,
2012. This matter is a core proceeding within the meaning of 28 U.S.C. § 157(b)(2). Venue is proper in this district pursuant to 28 U.S.C. §§ 1408 and 1409.
2. The statutory and other bases for the relief requested herein are sections 330 and
331 of chapter 11 of title 11 of the United States Code, 11 U.S.C. §§ 101–1532 (the “Bankruptcy
Code”), rule 2016 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), rule
2016-2 of the Local Rules of Bankruptcy Practice and Procedure of the United States Bankruptcy
Court for the District of Delaware (the “Local Rules”), and the Order (I) Approving Procedures for (A) Interim Compensation and Reimbursement of Expenses of Retained Professionals and
(B) Expense Reimbursement for Official Committee Members and (II) Granting Related Relief
[Docket No. 341] (the “Compensation Procedures Order”).
BACKGROUND
3. On February 18, 2020 (the “Petition Date”), each of the Debtors filed a voluntary petition with the Court for relief under chapter 11 of the Bankruptcy Code. The Debtors continue to operate and maintain their non-profit organization and manage their properties as debtors in possession pursuant to sections 1107(a) and 1108 of the Bankruptcy Code. On February 19, 2020, the Court entered an order [Docket No. 61] authorizing the joint administration and procedural consolidation of the chapter 11 cases pursuant to Bankruptcy Rule 1015(b).
4. The Debtors retained Ogletree Deakins as their special litigation counsel, nunc pro tunc to the Petition Date, pursuant to the Order Authorizing the Retention and Employment of
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Ogletree, Deakins, Nash, Smoak & Stewart, P.C. as Special Litigation Counsel for the Debtors and Debtors in Possession, Nunc Pro Tunc to the Petition Date [Docket No. 364] (the “Retention
Order”). The Retention Order authorizes the Debtors to compensate and reimburse Ogletree
Deakins in accordance with the terms and conditions set forth in the Debtors’ application to retain
Ogletree Deakins, subject to Ogletree Deakins’ application to the Court.
5. On April 6, 2020, the Court entered the Compensation Procedures Order. The
Compensation Procedures Order provides, among other things, that each professional shall be entitled, on or as soon as practicable after the fifteenth (15th) day of each month following the month for which compensation and/or expense reimbursement is sought, to file and serve an application for interim allowance of compensation earned and reimbursement of expenses incurred during the preceding month (each a “Monthly Fee Application”). Parties shall have fourteen (14) days after service of a Monthly Fee Application to file an objection to the compensation or expenses that are the subject thereof (the “Objection Deadline”). Upon the expiration of the
Objection Deadline, the applicant may file a certificate of no objection (a “CNO”) with the Court with respect to the unopposed portion of the fees and/or expenses requested in the applicable
Monthly Fee Application. After the filing of a CNO, the Debtors are authorized and directed to pay the applicant an amount equal to 80% of the fees and 100% of the expenses requested in the applicable Monthly Fee Application not subject to an objection.
RELIEF REQUESTED
6. By this Application, in accordance with the Compensation Procedures Order,
Ogletree Deakins requests payment in the aggregate amount of $103,968.56, which is equal to
(a) 80% of the $129,960.70 of total compensation earned by Ogletree Deakins during the Fee
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Period for its services to the Debtors and (b) 100% of the $100.31 of necessary expenses incurred by Ogletree Deakins during the Fee Period in connection with its services to the Debtors.
SUMMARY OF SERVICES RENDERED
7. Attached hereto as Exhibit A is a detailed statement of the time expended and compensation earned by Ogletree Deakins during the Fee Period with respect to Phase 1 tasks
(Litigation/Claims). Attached hereto as Exhibit B is a detailed statement of the time expended and compensation earned by Ogletree Deakins during the Fee Period with respect to Phase 2 tasks
(Retention Issues). Ogletree Deakins’ professionals expended a total of 345.2 hours in connection with these chapter 11 cases during the Fee Period. All services for which Ogletree Deakins is requesting compensation were performed for or on behalf of the Debtors. The services rendered by Ogletree Deakins during the Fee Period are categorized as set forth in Exhibit A and in the summary cover sheets prefixed to this Application. The professionals who provided services to the Debtors during the Fee Period are also identified in Exhibit A and in the summary cover sheets.
ACTUAL AND NECESSARY EXPENSES
8. Ogletree Deakins also incurred certain necessary expenses during the Fee Period for which it is entitled to reimbursement under the terms of its retention. As set forth in greater detail in the detailed statements attached hereto as Exhibits A and B and the expense summary attached hereto as Exhibit C, Ogletree Deakins’ total expenses incurred during the Fee Period are
$100.31.
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 $129,960.70.
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10. In accordance with section 330 of the Bankruptcy Code, the fees requested are reasonable in light of factors including, among other things, (a) the complexity of these chapter 11 cases, (b) the time expended, (c) the nature and extent of the services rendered, (d) the value of such services, and (e) the costs of comparable services other than in a case under this title.
11. Although Ogletree Deakins has made every effort to include all fees and expenses incurred during the Fee Period in this Application, some fees and expenses might have been omitted from this Application due to delays caused by accounting and processing during the Fee
Period. Ogletree Deakins reserves the right to submit further applications to the Court for allowance of such fees and expenses not included herein. Subsequent fee applications will be filed in accordance with the requirements of the Bankruptcy Code, the Bankruptcy Rules, the Local
Rules, and the Compensation Procedures Order.
CERTIFICATION OF COMPLIANCE
12. The undersigned has reviewed the requirements of Local Rule 2016-2 and certifies that, to the best of his knowledge, information and belief, this Application complies with that rule.
[Remainder of Page Intentionally Left Blank]
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WHEREFORE, Ogletree Deakins requests payment in the aggregate amount of
$103,968.56, which is equal to (a) 80% of the $129,960.70 of total compensation earned by
Ogletree Deakins during the Fee Period for its services to the Debtors and (b) 100% of the $100.31 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 $104,068.87.
Dated: October 1, 2020 Ogletree, Deakins, Nash, Smoak & Austin, Texas Stewart, P.C.
/s/ Bruce A. Griggs Bruce A. Griggs Shareholder 301 Congress Avenue, Suite 1150 Austin, Texas 78701 Phone: (512) 344-4700 Email: [email protected]
SPECIAL LITIGATION COUNSEL TO THE DEBTORS AND DEBTORS IN POSSESSION
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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE
In re Chapter 11
Boy Scouts of America, et al., Case No. 20-10343 (LSS)
Debtors.1 Jointly Administered
Objection Deadline: October 15, 2020, at 4:00 p.m. (ET)
NOTICE OF SIXTH MONTHLY APPLICATION OF OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C. FOR ALLOWANCE OF COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR THE PERIOD FROM AUGUST 1, 2020 TO AUGUST 31, 2020
PLEASE TAKE NOTICE that today, Ogletree, Deakins, Nash, Smoak & Stewart, P.C., as special litigation counsel to the Debtors in the above-captioned cases, filed the attached Sixth Monthly Application of Ogletree, Deakins, Nash, Smoak & Stewart, P.C. for Allowance of Compensation and Reimbursement of Expenses for the Period from August 1, 2020 to August 31, 2020 (the “Application”).
PLEASE TAKE FURTHER NOTICE that objections, if any, to the Application, must: (a) be filed with the Clerk of the Bankruptcy Court, 824 North Market Street, 3rd Floor, Wilmington, Delaware 19801, by October 15, 2020, at 4:00 p.m. (Eastern Time) (the “Objection Deadline”); and (b) be served so as to be received on or before the Objection Deadline by:
i. the Applicant: Ogletree, Deakins, Nash, Smoak & Stewart, P.C., 301 Congress Avenue, Suite 1150, Austin, Texas 78701, Attn: Bruce A. Griggs;
ii. the Debtors: Boy Scouts of America, 1325 West Walnut Hill Lane, Irving, Texas 75038, Attn: Steven P. McGowan;
iii. counsel to the Debtors: Sidley Austin LLP, 787 Seventh Avenue, New York, New York 10019, Attn: Jessica C.K. Boelter and One South Dearbon, Chicago, Illinois 60603 Attn: Matthew E. Linder;
1 The Debtors in these cases, along with the last four digits of each Debtor’s federal EIN, are as follows: Boy Scouts of America (6300) and Delaware BSA, LLC (4311). The Debtors’ mailing address is 1325 West Walnut Hill Lane, Irving, Texas 75038.
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iv. co-counsel to the Debtors: Morris, Nichols, Arsht & Tunnell LLP, 1201 N. Market Street, 16th Floor, Wilmington, DE 19801, Attn: Derek C. Abbott;
v. the Office of the United States Trustee: J. Caleb Boggs Federal Building, Room 2207, 844 N. King Street, Wilmington, DE 19801, Attn: David Buchbinder and Hannah M. McCollum;
vi. counsel to the Creditors’ Committee, Kramer Levin Naftalis & Frankel LLP, 1177 Avenue of the Americas, New York, New York 10036, Attn: Rachael Ringer and Megan M. Wasson;
vii. counsel to the Tort Claimants’ Committee, Pachulski Stang Ziehl & Jones LLP, 10100 Santa Monica Boulevard, 13th Floor, Los Angeles, California 90067, Attn: James I. Stang;
viii. counsel to the Future Claimants’ Representative, Young Conaway Stargatt & Taylor, LLP, Rodney Square, 1000 North King Street, Wilmington, Delaware 19801, Attn: Robert S. Brady and Edwin J. Harron;
ix. counsel to the Ad Hoc Committee of Local Councils, Wachtell, Lipton, Rosen & Katz, 51 West 52nd Street, New York, New York 10019, Attn: Richard G. Mason and Joseph C. Celentino;
x. counsel to JPMorgan Chase Bank, National Association, Norton Rose Fulbright US LLP, 2200 Ross Avenue, Dallas, Texas 75201-7932, Attn: Louis R. Strubeck and Kristian W. Gluck; and
xi. counsel to the County Commission of Fayette County (West Virginia), Steptoe & Johnson PLLC, Chase Tower – 8th Floor, 707 Virginia Street East, Charleston, West Virginia 25301, Attn: John Stump.
A HEARING ON THE APPLICATION, IF NECESSARY, WILL BE HELD AT THE CONVENIENCE OF THE COURT AND NOTICE OF ANY SUCH HEARING WILL BE GIVEN ONLY TO THE OBJECTING PARTY OR PARTIES.
IF YOU FAIL TO RESPOND IN ACCORDANCE WITH THIS NOTICE, THE COURT MAY GRANT THE RELIEF REQUESTED BY THE APPLICATION WITHOUT FURTHER NOTICE OR HEARING.
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Dated: October 1, 2020 MORRIS, NICHOLS, ARSHT & TUNNELL LLP Wilmington, Delaware /s/ Eric W. Moats Derek C. Abbott (No. 3376) Andrew R. Remming (No. 5120) Eric W. Moats (No. 6441) Paige N. Topper (No. 6470) 1201 North Market Street, 16th Floor P.O. Box 1347 Wilmington, Delaware 19899-1347 Telephone: (302) 658-9200 Facsimile: (302) 425-4664 Email: [email protected] [email protected] [email protected] [email protected]
– and –
SIDLEY AUSTIN LLP Jessica C. K. Boelter (admitted pro hac vice) 787 Seventh Avenue New York, New York 10019 Telephone: (212) 839-5300 Email: [email protected]
– and –
SIDLEY AUSTIN LLP Thomas A. Labuda (admitted pro hac vice) Michael C. Andolina (admitted pro hac vice) Matthew E. Linder (admitted pro hac vice) One South Dearborn Street Chicago, Illinois 60603 Telephone: (312) 853-7000 Email: [email protected] [email protected] [email protected]
ATTORNEYS FOR DEBTORS AND DEBTORS IN POSSESSION
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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 September 15, 2020 Telephone: (864) 241-1801 Facsimile: (864) 241-1908
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 # 90275792 Client.Matter # 047657.000013
Re: BSA General Defense - Bankruptcy (Billiable)
For professional services rendered through August 31, 2020, in connection with the above-referenced matter as outlined on the attached detailed billing sheets:
Fees ...... $115,452.50 Expenses...... $81.19
Total Due This Bill...... $115,533.69
Atlanta ▪ Austin ▪ Berlin (Germany) ▪ Birmingham ▪ Boston ▪ Charleston ▪ Charlotte ▪ Chicago ▪ Cleveland ▪ Columbia ▪ Dallas ▪ Denver ▪ Detroit Metro ▪ Greenville ▪ Houston Indianapolis ▪ Jackson ▪ Kansas City ▪ Las Vegas ▪ London (England) ▪ Los Angeles ▪ Memphis ▪ Mexico City (Mexico) ▪ Miami ▪ Milwaukee ▪ Minneapolis ▪ Montréal (Canada) ▪ Morristown Nashville ▪ New Orleans ▪ New York City ▪ Oklahoma City ▪ Orange County ▪ Paris (France) ▪ Philadelphia ▪ Phoenix ▪ Pittsburgh ▪ Portland, ME ▪ Portland, OR ▪ Raleigh Richmond ▪ St. Louis ▪ St. Thomas ▪ Sacramento ▪ San Antonio ▪ San Diego ▪ San Francisco ▪ Seattle ▪ Stamford ▪ Tampa ▪ Toronto (Canada) ▪ Torrance ▪ Tucson ▪ Washington Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 3 of 74
Page 2 09/15/20 Bill No. 90275792 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 August 31, 2020
Date Initials Stage Description Hours Amount 08/03/20 BAG PHASE1 Review final dismissal order in Cote v 0.10 64.00 BSA. 08/03/20 BAG PHASE1 Review memorandum and incident 0.20 128.00 survey in J.C. v BSA and attention to same. 08/03/20 SEM PHASE1 Telephone call with Hudson Valley 0.30 133.50 Council in New York regarding new lawsuit filed there and affect on chartered organization named in case and research into other newly filed lawsuits against the council. 08/03/20 SEM PHASE1 Review new media reports related to 0.20 89.00 several new lawsuits being filed in New York and summarize information from the same. 08/03/20 SEM PHASE1 Email to BSA with final dismissal in 0.10 44.50 the Cote case in New Hampshire. 08/03/20 SEM PHASE1 Email to South Florida Council 0.20 89.00 seeking information related to AIS- 0676 claim. 08/03/20 SEM PHASE1 Review press release from New York 0.20 89.00 Governor's Office regarding extension of Child Victims Act extension being signed and send same to BSA. 08/03/20 SEM PHASE1 Review BSA internal file for alleged 1.20 534.00 perpetrator (and his father) in new John Doe 34 C.P. case filed in New York. Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 4 of 74
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Date Initials Stage Description Hours Amount 08/03/20 SEM PHASE1 Review J.C. case in Virginia and draft 2.10 934.50 a summary of the incident to provide Old Republic Insurance in relation to the individual Scoutmaster's request for defense and indemnity. 08/03/20 SEM PHASE1 Email exchange with BSA regarding a 0.20 89.00 detailed incident report and status of J.C. case in Virginia for sending to Old Republic Insurance in regard to Scoutmaster Thomas Scott's request for indemnity. 08/03/20 SEM PHASE1 Email exchange with California Inland 0.20 89.00 Empire Council regarding information related to BSA internal file project request. 08/03/20 SEM PHASE1 Email from South Florida Council with 0.20 89.00 information and documents related to BSA internal file project claim research and review the same. 08/03/20 SEM PHASE1 Email exchange with Sidley regarding 0.20 89.00 research memorandum related to state statutes of limitations. 08/03/20 SEM PHASE1 Email to Haynes & Boone to follow-up 0.10 44.50 on status of response to co-defendant perpetrator's request for defense in the Lopez case in New York. 08/03/20 SEM PHASE1 Review additional documents and 1.20 534.00 information and revise J.C. v. Blue Ridge Mountains Council incident summary based on BSA request for additional information. 08/03/20 SEM PHASE1 Review multiple emails and letters 0.20 89.00 denying coverage for the Berry, Baker and various unrelated claims, received from Everest Insurance. 08/03/20 SEM PHASE1 Email from Sidley with information 0.30 133.50 from Plaintiff's counsel regarding re- filings in four New York lawsuits and forward same to local New York defense counsel handling the same. 08/03/20 SEM PHASE1 Begin to organize, review and create 1.50 667.50 Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 5 of 74
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Date Initials Stage Description Hours Amount a chart for summary of 84 new lawsuits filed in New York last week in 14 different local councils. 08/03/20 SEM PHASE1 Email exchange with Seneca 0.20 89.00 Waterways Council regarding new lawsuits filed against them, responses to the same, and need to obtain actual plaintiff names. 08/03/20 KAD PHASE1 Review emails from Vanessa Savoy 0.10 19.00 regarding changes to Riskonnect and month-end reporting. 08/03/20 KAD PHASE1 Review news article regarding 0.10 19.00 Governor Cuomo signing legislation extending look-back window for the child victims act. 08/03/20 KAD PHASE1 Continue revising Schedule 1 Chart 7.20 1,368.00 of Pending Abuse Actions. 08/03/20 KAD PHASE1 Review email from Karim Basaria 0.10 19.00 regarding correspondence received from the plaintiffs' lawyer in four New York cases. 08/03/20 KAD PHASE1 Review court's order dismissing Cote 0.10 19.00 case. 08/04/20 BAG PHASE1 Review draft paper to be published by 0.50 320.00 Dr. Janet Warren and exchange email with Steve McGowan regarding same. 08/04/20 BAG PHASE1 Review reports regarding 120 new 0.50 320.00 claims filed in New York and internal team meeting/discussion and handling of same. 08/04/20 BAG PHASE1 Begin review of selected complaints 2.50 1,600.00 to determine allegations, dates of abuse, and level of investigation required. 08/04/20 SEM PHASE1 Email exchange with South Florida 0.20 89.00 Council regarding council attorney position on time barred claims. 08/04/20 SEM PHASE1 Email from Greater Tampa Bay Area 0.20 89.00 Council with information and Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 6 of 74
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Date Initials Stage Description Hours Amount documents in response to BSA internal file project request and review the same. 08/04/20 SEM PHASE1 Email from Montana defense counsel 0.20 89.00 with copies of filed Acknowledgements of Service for seven (7) of the new lawsuits there and review the same. 08/04/20 SEM PHASE1 Email exchange with Sidley regarding 0.20 89.00 the status of the Schedule 1 update and the number of new lawsuits being added. 08/04/20 SEM PHASE1 Receive and review five (5) emails 0.20 89.00 from the Seneca Waterways Council with new lawsuits and information regarding the same. 08/04/20 SEM PHASE1 Continue reviewing 85 new lawsuits 4.00 1,780.00 in the State of New York and process same for the councils and investigation of the same. 08/04/20 SEM PHASE1 Review multiple emails and 0.20 89.00 correspondence from Everest Insurance with coverage positions on several different new claims and review same. 08/04/20 SEM PHASE1 Review claims information update 0.10 44.50 provided by Kelci Davis. 08/04/20 SEM PHASE1 Email from Great Southwest Council 0.10 44.50 responding to BSA internal file project request for information related to AIS- 0358 claim. 08/04/20 SEM PHASE1 Email from Seneca Waterways 0.20 89.00 Council with information and documents related to AB 410 DOE lawsuit, review and forward same to BSA. 08/04/20 SEM PHASE1 Email from Seneca Waterways 0.20 89.00 Council with information and documents related to AB 426 DOE lawsuit, review and forward same to BSA. Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 7 of 74
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Date Initials Stage Description Hours Amount 08/04/20 SEM PHASE1 Email from Westchester-Putnam 0.20 89.00 Council with information and documents related to new lawsuits filed in New York, review and forward same to BSA. 08/04/20 SEM PHASE1 Second email from Westchester- 0.20 89.00 Putnam Council with information and documents related to additional new lawsuits filed in New York, review and forward same to BSA. 08/04/20 SEM PHASE1 Email to Sidley with amended 0.10 44.50 Schedule 1 for attachment to newest amended Consent Order filing. 08/04/20 SEM PHASE1 Email exchange with California Inland 0.20 89.00 Empire Council regarding documents and information related to BSA internal file project request, review and forward same to BSA. 08/04/20 SEM PHASE1 Email exchange with BSA and Blue 0.30 133.50 Ridge Mountain Council regarding Scout Executive notes from J.C. case in Virginia and review same for inclusion in incident summary to provide BSA insurance carrier. 08/04/20 SEM PHASE1 Revise case status and incident 0.20 89.00 memorandum in J.C. case in Virginia to include additional information received from Blue Ridge Mountain council. 08/04/20 SEM PHASE1 Research proper local BSA council 0.10 44.50 for AIS-0358 claim previously assigned to Great Southwest Council for redirecting the same. 08/04/20 SEM PHASE1 Email to Michigan Crossroads 0.20 89.00 Council with re-assigned AIS-0358 claim and request for information for the same. 08/04/20 SEM PHASE1 Email exchange with Seneca 0.20 89.00 Waterways Council regarding five (5) additional lawsuits filed in New York against their council today. Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 8 of 74
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Date Initials Stage Description Hours Amount 08/04/20 SEM PHASE1 Review letters sent anonymously to 0.30 133.50 the Greater Niagara Frontier Council regarding the Scott Miller Lawsuit and email council regarding a prior similar letter. 08/04/20 KAD PHASE1 Search for and analyze historical 0.40 76.00 Complaint filed in 1990 per Jennifer Nichols request. 08/04/20 KAD PHASE1 Email Jennifer Nichols summarizing 0.10 19.00 the allegations from the 1990 Complaint. 08/04/20 KAD PHASE1 Email exchange with Tina Sunderland 0.10 19.00 regarding Acknowledgments of Service signed for various Montana cases. 08/04/20 KAD PHASE1 Email exchange with Andres Barajas 0.10 19.00 regarding Schedule 1 Chart of Pending Abuse Actions. 08/04/20 KAD PHASE1 Finish revising Schedule 1 Chart of 5.30 1,007.00 Pending Abuse Actions. 08/04/20 KAD PHASE1 Review multiple emails from Anna 0.10 19.00 Kutz regarding new lawsuits filed in New York. 08/04/20 KAD PHASE1 Calculate claims data in preparation 1.40 266.00 of conference call with attorneys to discuss strategy for handling same. 08/05/20 BAG PHASE1 Initial review of 45 New York Cases 4.50 2,880.00 filed on August 4 and internal communications with Sean Manning and Kelci Davis regarding planned investigation and response. 08/05/20 SEM PHASE1 Continue reviewing 85 new lawsuits 7.80 3,471.00 filed in New York last week and summarize same for the BSA local councils for use in research requests for same. 08/05/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 Scouts Canada case and information obtained from the Cradle of Liberty Council. Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 9 of 74
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Date Initials Stage Description Hours Amount 08/05/20 SEM PHASE1 Email from Hawkeye Area Council 0.20 89.00 with information and records related to BSA internal file project request and review the same. 08/05/20 SEM PHASE1 Email from Blue Ridge Mountain 0.10 44.50 Council regarding request for council file related to J.C. lawsuit and obtaining the same. 08/05/20 SEM PHASE1 Email discussion with Greater Los 0.30 133.50 Angeles Area Council and their auditor regarding audit response and forward same. 08/05/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 an update on the status of the investigation of the new Powers case in Pennsylvania. 08/05/20 KAD PHASE1 Review letters from an anonymous 0.10 19.00 reporter regarding Scott Miller lawsuit. 08/05/20 KAD PHASE1 Analyze lawsuit filed by Richard 0.20 38.00 Powers in preparation of entering same in Riskonnect. 08/05/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by Richard Powers. 08/05/20 KAD PHASE1 Analyze lawsuit filed by John 0.20 38.00 DeVanney in preparation of entering same in Riskonnect. 08/05/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by John DeVanney. 08/05/20 KAD PHASE1 Analyze lawsuit filed by Brian Eller in 0.20 38.00 preparation of entering same in Riskonnect. 08/05/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by Brian Eller. 08/05/20 KAD PHASE1 Analyze lawsuit filed by Ty Klipstein 0.20 38.00 in preparation of entering same in Riskonnect. 08/05/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by Ty Klipstein. Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 10 of 74
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Date Initials Stage Description Hours Amount 08/05/20 KAD PHASE1 Analyze lawsuit filed by Pablo Dilone 0.20 38.00 in preparation of entering same in Riskonnect. 08/05/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by Pablo Dilone. 08/05/20 KAD PHASE1 Email exchange with Anna Kutz 0.10 19.00 regarding completion of service in Richard Powers lawsuit and updating Riskonnect with same. 08/06/20 BAG PHASE1 Continue review and analysis of 5.50 3,520.00 multiple New York complaints filed during the week of August 3. 08/06/20 BAG PHASE1 Exchange email with New York 0.20 128.00 defense counsel regarding new complaints. 08/06/20 BAG PHASE1 Review letter sent to counsels by tort 0.20 128.00 committee and exchange email with Anna Kutz regarding same. 08/06/20 SEM PHASE1 Email from Seneca Waterways 0.20 89.00 Council in New York with information and documents related to the newly filed AB 421 lawsuit, review same and forward to BSA. 08/06/20 SEM PHASE1 Email from Seneca Waterways 0.20 89.00 Council in New York with information and documents related to the newly filed AB 411 lawsuit and review same. 08/06/20 SEM PHASE1 Email from Seneca Waterways 0.20 89.00 Council in New York with information and documents related to the newly filed AB 416 lawsuit, review same and forward to BSA. 08/06/20 SEM PHASE1 Email exchange with Baden Powell 0.30 133.50 Council regarding new lawsuit for John Doe 17 R.H. and information suggesting this is NOT a BSA case. 08/06/20 SEM PHASE1 Compile perpetrator data from new 0.30 133.50 lawsuits from New York processed form the last week and submit a request for a search for BSA internal Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 11 of 74
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Date Initials Stage Description Hours Amount files for the same to review as part of new case investigation. 08/06/20 SEM PHASE1 Email to Rip Van Winkle Council 0.30 133.50 seeking information related to the John Doe 17 R.H. and request for information and documents related to the same with background on the case and position that it may not be a BSA unit. 08/06/20 SEM PHASE1 Email to local defense counsel to 0.10 44.50 advise that the Michael Sinsel case has been served on the Greater Niagara Frontier Council. 08/06/20 SEM PHASE1 Email to Melick & Porter to assign 1.00 445.00 numerous new lawsuits filed in the last week in New York and to provide background on the same. 08/06/20 SEM PHASE1 Email from Rip Van Winkle Council 0.20 89.00 confirming the new Michael Dunham case has been erroneously filed against the BSA and review information regarding the same. 08/06/20 SEM PHASE1 Email to local New York defense 0.40 178.00 counsel with direction to reach out to Plaintiff's counsel in the John Doe 17 R.H. case regarding voluntary dismissal as BSA is an improper party and to provide supporting research regarding the same. 08/06/20 SEM PHASE1 Email from Garden State Council with 0.20 89.00 information related to BSA internal file project request, review same and forward to BSA. 08/06/20 SEM PHASE1 Email to Wiggin & Dana to assign 0.80 356.00 numerous new lawsuits filed in the last week in New York and to provide background on the same. 08/06/20 SEM PHASE1 Begin sending emails to local BSA 1.00 445.00 councils with copies of new lawsuits filed against them with summaries of the same and requests for information in initial investigation. Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 12 of 74
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Date Initials Stage Description Hours Amount 08/06/20 SEM PHASE1 Email exchange with California Inland 0.30 133.50 Empire Council regarding letter from TCC, review same and forward to BSA for input. 08/06/20 SEM PHASE1 Email from Theodore Roosevelt 0.10 44.50 Council in New York advising they were unable to locate records related to the newly filed Porchenick case. 08/06/20 SEM PHASE1 Email from Baden Powell Council in 0.10 44.50 New York regarding their search for records related to the John Doe 32 H.T. case. 08/06/20 SEM PHASE1 Review emails from BSA and Sidley 0.20 89.00 in response to TCC letter to councils and response to the same. 08/06/20 SEM PHASE1 Email exchange with New Jersey 0.20 89.00 defense counsel regarding upcoming case management conference in the Lopez case. 08/06/20 SEM PHASE1 Email exchange with New Jersey 0.20 89.00 defense counsel regarding talking points and information to present at upcoming case management conference in the Lopez case. 08/06/20 SEM PHASE1 Conference call with Haynes & Boone 0.80 356.00 regarding update on status of the bankruptcy case and concerns about impacts on local councils and new insurance matters. 08/06/20 SEM PHASE1 Email exchange with California 0.20 89.00 defense counsel regarding information from plaintiff's counsel and authority to accept service on new lawsuits. 08/06/20 SEM PHASE1 Emails to California local BSA 0.20 89.00 councils seeking authority for our local defense counsel to accept service on their behalf. 08/06/20 SEM PHASE1 Email to BSA with summary of 0.10 44.50 information obtained from conference call with Haynes & Boone. Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 13 of 74
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Date Initials Stage Description Hours Amount 08/06/20 SEM PHASE1 Email from Greater New York 0.20 89.00 Councils confirming the council sits partly in Kings County and forward same to local defense counsel. 08/06/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 the John Doe 17 R.H. case and whether it is a BSA case or not. 08/06/20 SEM PHASE1 Review 51 page BSA internal file for 0.80 356.00 Michael Dunham in regard to the John Doe 17 R.H. case in New York and communicate with BSA, the Baden Powell Council and local defense counsel regarding information obtained from review and need to clarify information with Plaintiff's counsel. 08/06/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 Seneca Waterways Scout Executive and his concerns about the new lawsuits being filed against his council. 08/06/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 potential break away of AIS claims group and continued need for them to submit proofs of claims. 08/06/20 KAD PHASE1 Update claim record in Riskonnect to 0.10 19.00 reflect service completed upon BSA in connection with the lawsuit filed by Richard Powers. 08/06/20 KAD PHASE1 Analyze rosters received from the 0.20 38.00 Council in connection with the AB 421 Doe lawsuit and email from Stephen Hoitt regarding same. 08/06/20 KAD PHASE1 Analyze rosters received from the 0.10 19.00 Council in connection with the AB Doe 411 lawsuit and email from Stephen Hoitt regarding same. 08/06/20 KAD PHASE1 Analyze roster received from the 0.10 19.00 Council in connection with the AB 416 Doe lawsuit and email from Stephen Hoitt regarding same. Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 14 of 74
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Date Initials Stage Description Hours Amount 08/06/20 KAD PHASE1 Identify New York cases assigned to 0.30 57.00 Lewis Brisbois to assist attorney with assigning newly received lawsuits to defense counsel. 08/06/20 KAD PHASE1 Review email from Anna Kutz 0.10 19.00 regarding the completion of service of process upon the Greater Niagara Frontier Council. 08/06/20 KAD PHASE1 Update claim record in Riskonnect to 0.10 19.00 reflect service completed upon BSA in connection with the lawsuit filed by Michael Sinsel. 08/06/20 KAD PHASE1 Calculate the number of New York 0.60 114.00 lawsuits assigned to each defense counsel to assist attorneys with assigning newly received lawsuits. 08/07/20 BAG PHASE1 Telephone conference with Anna 0.20 128.00 Kutz regarding status and pending claims. 08/07/20 BAG PHASE1 Review remand order in Hartford 0.30 192.00 coverage litigation and exchange email Adrian Azer regarding same. 08/07/20 BAG PHASE1 Conference call with Wiggin & Dana 0.30 192.00 to discuss New York claims and overall status. 08/07/20 SEM PHASE1 Email exchange with Western Los 0.20 89.00 Angeles County Council agreement to have California defense council accept service for them and regarding known lawsuits. 08/07/20 SEM PHASE1 Email with BSA regarding access to 0.20 89.00 BSA internal files and adding victim information into existing internal files. 08/07/20 SEM PHASE1 Review charts and complaints sent to 0.20 89.00 Melick & Porter and Wiggin & Dana and email both regarding confirmation of assignment of the same. 08/07/20 SEM PHASE1 Continue drafting emails to New York 1.60 712.00 local councils with notices of new lawsuits and requests for information Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 15 of 74
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Date Initials Stage Description Hours Amount related to investigations of same. 08/07/20 SEM PHASE1 Conference call with Wiggin & Dana, 0.40 178.00 New York defense counsel regarding logistics of handling the influx of new lawsuits there and to provide an update on the BSA bankruptcy situation. 08/07/20 SEM PHASE1 Email from Theodore Roosevelt 0.20 89.00 Council in New York with information and documents related to new lawsuits filed against them and review the same. 08/07/20 SEM PHASE1 Email discussion with Haynes & 0.30 133.50 Boone regarding BSA v. Hartford remand order and affect on BSA bankruptcy case. 08/07/20 SEM PHASE1 Review Weekly New Abuse Claims 0.10 44.50 report prepared by Kelci Davis. 08/07/20 SEM PHASE1 Review 23 page BSA v. Hartford 0.50 222.50 Insurance Remand Order. 08/07/20 SEM PHASE1 Email from Seneca Waterways 0.10 44.50 Council in New York with information related to new lawsuit filed today. 08/07/20 SEM PHASE1 Review all new New York lawsuits 0.40 178.00 filed this week, still not processed and summarized and prepare case tracking spreadsheet to include same. 08/07/20 SEM PHASE1 Email from New Hampshire defense 0.10 44.50 counsel with court order terminating the Cote case. 08/07/20 KAD PHASE1 Email Sidley Austin, Alvarez Marsal, 1.00 190.00 BSA and Monica Blacker regarding weekly new abuse claims report. 08/07/20 KAD PHASE1 Conference call with James Glasser, 0.40 76.00 Mike Kenny, Bruce Griggs and Sean Manning regarding status of the bankruptcy proceeding and the influx of new cases being filed in New York. 08/07/20 KAD PHASE1 Prepare weekly new claims report. 6.70 1,273.00 Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 16 of 74
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Date Initials Stage Description Hours Amount 08/10/20 BAG PHASE1 Review email from Adrian Azer 0.10 64.00 regarding request for indemnity in Lopez v BSA. 08/10/20 BAG PHASE1 Review status report from defense 0.20 128.00 counsel in Lopez v BSA. 08/10/20 BAG PHASE1 Initial internal team communications 2.50 1,600.00 to review and analyze new claims received and begin work on investigation of same. 08/10/20 SEM PHASE1 Email from client seeking a 0.10 44.50 conference call to discuss proposed judge application. 08/10/20 SEM PHASE1 Email exchange with Greater Los 0.20 89.00 Angeles Area Council regarding approval for local defense counsel to accept service on their part and continued communication regarding new lawsuits. 08/10/20 SEM PHASE1 Review additional new lawsuits filed 0.80 356.00 in New York last week and summarize same for local councils and investigation of the same. 08/10/20 SEM PHASE1 Email exchange with Virginia defense 0.30 133.50 counsel regarding the former Scoutmaster defendant's demand for defense and indemnity and forward status request to BSA regarding Blue Ridge Mountain Council information. 08/10/20 SEM PHASE1 Email discussion with California 0.40 178.00 defense counsel regarding potential objection to stay by Plaintiff in new Western Los Angeles County Council lawsuit and need to file response to said lawsuit. 08/10/20 SEM PHASE1 Email exchange with Baden Powell 0.30 133.50 Council in New York regarding service of process in the Armstrong lawsuit and notify local defense counsel of the same. 08/10/20 SEM PHASE1 Email discussion with BSA regarding 0.40 178.00 the coverage and policy issues Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 17 of 74
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Date Initials Stage Description Hours Amount related to the former Scoutmaster's request for indemnity and defense in the J.C. case in Virginia. 08/10/20 SEM PHASE1 Email to Virginia defense counsel 0.20 89.00 regarding our position on the coverage and policy issues related to the former Scoutmaster's request for indemnity and defense in the J.C. case in Virginia and a response to him about the same. 08/10/20 SEM PHASE1 Review report from New Jersey 0.10 44.50 defense counsel regarding hearing on whether BSA litigation stay applies to all parties and order allowing discovery against the alleged perpetrator in the Lopez case. 08/10/20 SEM PHASE1 Email exchange with the Great Trail 0.30 133.50 Council regarding information and records in response to BSA internal file project request, and review and forward same to BSA. 08/10/20 SEM PHASE1 Email from Suffolk County Council 0.30 133.50 with information and records related to the new John Doe N.C. case, and review and forward same to BSA. 08/10/20 SEM PHASE1 Review email from attorney for the 0.10 44.50 Connecticut Yankee Council to BSA insurance coverage counsel seeking information related to council coverage matters. 08/10/20 SEM PHASE1 Email from Westchester-Putnam 0.20 89.00 Council in New York advising they have no information regarding newly filed lawsuits against their council and forward same to BSA. 08/10/20 SEM PHASE1 Email from Kentucky defense counsel 0.20 89.00 with Joint Motion to Stay Action as to Defendant Fleming filed in LFL cases and review same. 08/10/20 SEM PHASE1 Review list of new lawsuits filed in 0.10 44.50 New York today against the local councils. Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 18 of 74
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Date Initials Stage Description Hours Amount 08/10/20 SEM PHASE1 Email from Suffolk County Council 0.10 44.50 regarding the possible identity of plaintiff John Doe N.C. 08/10/20 KAD PHASE1 Communicate with Jennifer Nicholos 0.10 19.00 via Chatter regarding alleged perpetrator in CJ - 00068 claim. 08/10/20 KAD PHASE1 Analyze CJ - 00068 claim to confirm 0.10 19.00 alleged perpetrator for client. 08/10/20 KAD PHASE1 Analyze and search BSA's internal 4.60 874.00 files for alleged perpetrators named in 75 newly filed New York lawsuits. 08/10/20 KAD PHASE1 Analyze lawsuit filed by John C Doe 0.20 38.00 in preparation of entering same in Riskonnect. 08/10/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by John C Doe. 08/10/20 KAD PHASE1 Email exchange with William Curtain 0.10 19.00 regarding newly filed lawsuits to add to Schedule 1. 08/10/20 KAD PHASE1 Analyze various complaints sent by 0.40 76.00 William Curtain and identify any new lawsuits Ogletree is not yet aware of. 08/10/20 KAD PHASE1 Analyze lawsuit filed by Donald 0.20 38.00 Hobbs in preparation of entering same in Riskonnect. 08/10/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by Donald Hobbs. 08/11/20 BAG PHASE1 Review email from Anna Kutz and 0.30 192.00 attached Complaint received in John Doe v BSA (Monroe County, NY) and attention to same. 08/11/20 BAG PHASE1 Review email from Anna Kutz 0.50 320.00 regarding Complaint received and claims asserted against Five Rivers Council in New York and internal communications with Sean Manning and Kelci Davis regarding same. 08/11/20 BAG PHASE1 Review email update from defense 0.10 64.00 counsel in J.C. v BSA (New York). Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 19 of 74
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Date Initials Stage Description Hours Amount 08/11/20 BAG PHASE1 Review Plaintiff's brief in support of 0.20 128.00 Motion to Compel in John Doe (NM) v BSA. 08/11/20 BAG PHASE1 Continue review of voluminous new 3.00 1,920.00 complaints filed in New York and internal communications with Sean Manning regarding same. 08/11/20 BAG PHASE1 Internal team meeting to discuss 0.50 320.00 pending claims and cases. 08/11/20 SEM PHASE1 Email exchange with Garden State 0.20 89.00 Council regarding summons' and Complaints received for Michael Kaminski and David Burdette lawsuits. 08/11/20 SEM PHASE1 Email discussion with BSA and Five 0.40 178.00 Rivers Council regarding new lawsuit for Peter Schwert and need to communicate with the Chartered Organization, Union University Church. 08/11/20 SEM PHASE1 Email to Union University Church to 0.30 133.50 introduce Ogletree and explain the background of the Consent Order in the BSA bankruptcy case and provide information regarding a response to the Peter Schwert lawsuit. 08/11/20 SEM PHASE1 Email from AIG Insurance with 0.20 89.00 reservation of rights related to KS- Doe 15 case in New York and review the same. 08/11/20 SEM PHASE1 Email from New Mexico defense 0.20 89.00 counsel with Plaintiff John Doe's Reply in support of First Motion to Compel Discovery and review the same. 08/11/20 SEM PHASE1 Email to New Jersey defense counsel 0.30 133.50 regarding service of process and entry of appearance and Notice of Stay in Burdette and Kaminski cases. 08/11/20 SEM PHASE1 Review newly filed and served Peter 0.60 267.00 M. Schwert lawsuit in New York, Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 20 of 74
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Date Initials Stage Description Hours Amount attempt to clarify proper venue and summary of claims. 08/11/20 SEM PHASE1 Email exchange with New York 0.20 89.00 defense counsel to follow-up on status of multiple lawsuits for KS-Doe 15. 08/11/20 SEM PHASE1 Email exchange with New Mexico 0.20 89.00 defense counsel regarding Plaintiff John Doe's request for an acceptance of service pleading and a response to the same. 08/11/20 SEM PHASE1 Review correspondence between 0.20 89.00 attorney for the Connecticut Yankee Council and Haynes & Boone regarding a request for BSA insurance coverage information. 08/11/20 SEM PHASE1 Review newly filed and served John 0.40 178.00 Doe 55 lawsuit in New York against the Seneca Waterways Council and summarize same for case tracking and investigation purposes. 08/11/20 SEM PHASE1 Email from New York counsel with 0.10 44.50 further update on KS-Doe-15 matter and resolution of the same. 08/11/20 SEM PHASE1 Email to New York defense counsel 0.20 89.00 to assign new Peter Schwert lawsuit and provide background on the same. 08/11/20 SEM PHASE1 Review list of new cases filed in New 0.90 400.50 York yesterday and add same to the New York lawsuit tracking spreadsheet for summary of claims to send to local councils and defense counsel. 08/11/20 SEM PHASE1 Email from New Jersey defense 0.20 89.00 counsel advising Pingry case of M.F. has been dismissed and review stipulation of dismissal. 08/11/20 SEM PHASE1 Email exchange with Melick and 0.20 89.00 Porter regarding establishing a conference call to discuss ongoing abuse litigation handling and Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 21 of 74
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Date Initials Stage Description Hours Amount bankruptcy case update. 08/11/20 SEM PHASE1 Begin reviewing new lawsuits filed in 2.00 890.00 New York for summarizing same to send to councils. 08/11/20 KAD PHASE1 Email exchange with Robyn Jungers 0.20 38.00 regarding John C Doe lawsuit and entering newly filed lawsuits in New York. 08/11/20 KAD PHASE1 Review email from Anna Kutz 0.10 19.00 regarding process of service upon Baden-Powell Council in connection with the lawsuit filed by Steven Armstrong. 08/11/20 KAD PHASE1 Update Steven Armstrong claim 0.10 19.00 record in Riskonnect to reflect completion of process of service on Baden-Powell Council. 08/11/20 KAD PHASE1 Analyze lawsuit filed by Marc 0.20 38.00 Porchenick in preparation of entering same in Riskonnect. 08/11/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by Marc Porchenick. 08/11/20 KAD PHASE1 Analyze lawsuit filed by James Kane 0.20 38.00 in preparation of entering same in Riskonnect. 08/11/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by James Kane. 08/11/20 KAD PHASE1 Review email from Stephen Hoitt 0.10 19.00 regarding lawsuit filed by John Doe 55 G.H. 08/11/20 KAD PHASE1 Review email from Anna Kutz 0.10 19.00 regarding new lawsuit filed by Peter Schwert and entering same into Riskonnect. 08/11/20 KAD PHASE1 Analyze lawsuit filed by AB 417 Doe 0.20 38.00 in preparation of entering same in Riskonnect. 08/11/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by AB 417 Doe. Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 22 of 74
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Date Initials Stage Description Hours Amount 08/11/20 KAD PHASE1 Analyze lawsuit filed by AB 410 Doe 0.20 38.00 in preparation of entering same in Riskonnect. 08/11/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by AB 410 Doe. 08/11/20 KAD PHASE1 Email exchange with Kathleen 0.10 19.00 Russell regarding Plaintiff John Doe’s (NM) Reply in support of First Motion to Compel Discovery, and the Notice of Completion of Briefing regarding same. 08/11/20 KAD PHASE1 Review Plaintiff John Doe’s (NM) 0.20 38.00 Reply in support of First Motion to Compel Discovery, and the Notice of Completion of Briefing regarding same. 08/11/20 KAD PHASE1 Communicate with Robyn Jungers via 0.20 38.00 Chatter regarding contact records needed for new plaintiffs' firms. 08/11/20 KAD PHASE1 Analyze lawsuit filed by AB 400 Doe 0.20 38.00 in preparation of entering same in Riskonnect. 08/11/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by AB 400 Doe. 08/12/20 BAG PHASE1 Review email and attached order 0.20 128.00 from Georgia defense counsel regarding notice filings in Georgia cases and attention to same. 08/12/20 BAG PHASE1 Conference call with Sean Manning 0.50 320.00 and New York defense counsel to discuss existing claims and cases and overall status. 08/12/20 BAG PHASE1 Review and analyze Complaint in 0.50 320.00 Morse v Town of Russell and attention to same. 08/12/20 BAG PHASE1 Exchange email with Steve McGowan 0.20 128.00 and Bill Curtin at Sidley Austin regarding Morse Complaint. 08/12/20 BAG PHASE1 Continue review and analysis of new 3.00 1,920.00 claims filed during the week of August Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 23 of 74
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Date Initials Stage Description Hours Amount 10. 08/12/20 SEM PHASE1 Email from Georgia defense counsel 0.20 89.00 with pleadings filed by co-defendant churches joining the BSA stay of litigation and review the same. 08/12/20 SEM PHASE1 Conference call with Melick & Porter 0.40 178.00 in New York regarding continuation of defense of ongoing litigation there and further cases coming there way. 08/12/20 SEM PHASE1 Review four new lawsuits filed in New 1.00 445.00 York that do not name BSA or a local council, investigate and add a summary of the same to the lawsuit tracking spreadsheet. 08/12/20 SEM PHASE1 Emails to New York councils seeking 0.20 89.00 to confirm chartered organization status for defendants in new lawsuits where BSA and councils were not named. 08/12/20 SEM PHASE1 Email from New Jersey defense 0.10 44.50 counsel with information that they filed the Notice of Second Extension of the Consent Order on the Kaminski and Burdette cases. 08/12/20 SEM PHASE1 Email exchange with BSA regarding 0.30 133.50 investigative information related to George Stanton case in New York and review information related to the case. 08/12/20 SEM PHASE1 Review email to BSA regarding 0.20 89.00 service of Block and Botsford lawsuits on the Seneca Waterways Council and notice of same from BSA. 08/12/20 SEM PHASE1 Email to New York defense counsel 0.20 89.00 to advise of service of Block and Botsford lawsuits on the Seneca Waterways Council and to file their entries of appearance and Notice of BSA stay of litigation and to provide background on the same. 08/12/20 SEM PHASE1 Telephone call from Leatherstocking 0.10 44.50 Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 24 of 74
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Date Initials Stage Description Hours Amount Council in New York with background information related to new lawsuits. 08/12/20 SEM PHASE1 Email from Leatherstocking Council in 0.20 89.00 New York with documents related to the new lawsuits filed against them as discussed on the phone and review the same. 08/12/20 SEM PHASE1 Email discussion with BSA and Sidley 0.30 133.50 Austin regarding investigation and action to take on lawsuits against chartered organizations without a named BSA entity. 08/12/20 SEM PHASE1 Review information and documents 0.30 133.50 received from the Greater New York Councils related to a number of new lawsuits filed against them and update the New York litigation tracking spreadsheet. 08/12/20 SEM PHASE1 Review information from BSA 0.10 44.50 regarding the BSA GLIP program and when chartered organizations became insured. 08/12/20 SEM PHASE1 Email from Greater New York 0.20 89.00 Councils regarding information related to Pablo Dilone and revise litigation tracking chart to include same. 08/12/20 SEM PHASE1 Email exchange with New Mexico 0.30 133.50 defense counsel regarding plaintiff's desire for an acceptance of service to file in the John Doe case and review the same. 08/12/20 SEM PHASE1 Continue reviewing new lawsuits filed 1.40 623.00 against New York local councils and update New York litigation tracking spreadsheet to include information from the same for sending to local councils. 08/12/20 KJM PHASE1 Analyze/review attorney 0.20 30.00 representation letter received in preparation for entering new claim into Riskonnect. (NJ- K.C). Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 25 of 74
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Date Initials Stage Description Hours Amount 08/12/20 KJM PHASE1 Create new claim in Riskonnect in 0.80 120.00 preparation for litigation per Anna Kutz request. (NJ- K.C.). 08/13/20 BAG PHASE1 Review and respond to email from 0.20 128.00 Sidley Austin regarding filing suggestion of bankruptcy in non- abuse case in New York and internal communications regarding same. 08/13/20 BAG PHASE1 Continue review and analysis of new 1.50 960.00 complaints filed in New York. 08/13/20 BAG PHASE1 Conference call with Georgia defense 0.50 320.00 counsel and Adrian Azar regarding conflicts issues. 08/13/20 SEM PHASE1 Telephone call from BSA insurer to 0.20 89.00 discuss general claims and litigation information and to direct to Haynes and Boone and BSA for further more specific questions. 08/13/20 SEM PHASE1 Email exchange with Sidley regarding 0.20 89.00 AMP non-abuse claim in New York and assigning same to file a Suggestion of Bankruptcy. 08/13/20 SEM PHASE1 Review email exchange between 0.20 89.00 BSA and Sidley regarding the AMP case and need for a Suggestion of Bankruptcy and review said Suggestion for assigning to New York defense counsel. 08/13/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 assignment of AMP case and filing a Suggestion of Bankruptcy to New York abuse defense counsel. 08/13/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 service of Blair and Ackerly cases on Westchester Putnam Council in New York. 08/13/20 SEM PHASE1 Email to New York defense counsel 0.10 44.50 with information that Blair and Ackerly cases have been served on the council with direction to file initial pleadings. Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 26 of 74
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Date Initials Stage Description Hours Amount 08/13/20 SEM PHASE1 Email to Westchester Putnam Council 0.10 44.50 to advise of service received on Blair and Ackerly and assigned to defense counsel. 08/13/20 SEM PHASE1 Email from Greater New York 0.20 89.00 Councils with information and documents related to JA-017 Doe lawsuit and review the same. 08/13/20 SEM PHASE1 Review request for documentation 0.30 133.50 related to Jane Doe matter in Michigan from third-party insurance carrier Markel, research and provide the same. 08/13/20 SEM PHASE1 Email from Longhouse Council in 0.20 89.00 New York with notice of service of process on the council in the Daniel Davis case and review the same. 08/13/20 SEM PHASE1 Email to BSA with service of process 0.10 44.50 information received from Longhouse Council regarding the Daniel Davis case. 08/13/20 SEM PHASE1 Email to New York defense counsel 0.20 89.00 with service of process documents received from the Longhouse Council in regard to the Daniel Davis case and authorize entry of appearance and filing of the Notice of Stay of Litigation. 08/13/20 SEM PHASE1 Email exchange with New Mexico 0.30 133.50 defense counsel regarding the Court's Order setting a hearing on Plaintiff's Motion to Compel Discovery from co-defendant Robert Lucero, review said order and direct defense counsel accordingly. 08/13/20 SEM PHASE1 Email exchange with BSA regarding 0.30 133.50 additional information to provide Markel insurance regarding the Jane Doe case in Michigan and forward said information as requested. 08/13/20 SEM PHASE1 Continue reviewing new lawsuits filed 1.80 801.00 in New York to add to the litigation Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 27 of 74
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Date Initials Stage Description Hours Amount tracking spreadsheet and for summary of the same to send to local councils for investigation of claims. 08/13/20 KAD PHASE1 Email exchange with Anna Kutz 0.10 19.00 regarding service of process on Westchester-Putnam Council with Richard Ackerly lawsuit and updating Riskonnect with same. 08/13/20 KAD PHASE1 Update Richard Ackerly claim record 0.10 19.00 in Riskonnect to reflect completion of service of process on Westchester- Putnam Council. 08/13/20 KAD PHASE1 Update William Blair claim record in 0.10 19.00 Riskonnect to reflect completion of service of process on Westchester- Putnam Council. 08/13/20 KAD PHASE1 Email exchange with Anna Kutz 0.10 19.00 regarding service of process on Westchester-Putnam Council with William Blair lawsuit and updating Riskonnect with same. 08/13/20 KAD PHASE1 Review lengthy email from Robyn 0.10 19.00 Jungers regarding Einstein Search in Riskonnect. 08/14/20 SEM PHASE1 Review correspondence from AIG 0.20 89.00 Insurance regarding reservations of rights in Priester and John Doe cases. 08/14/20 SEM PHASE1 Complete review of new lawsuits filed 1.90 845.50 in New York for adding to the New York lawsuit tracking spreadsheet and summarization of cases to send to local councils with requests for information related to the same. 08/14/20 SEM PHASE1 Review information received 0.80 356.00 regarding perpetrators alleged in newly filed New York lawsuits and identify those with BSA internal files and revise New York litigation tracking sheet with information related to the same. Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 28 of 74
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Date Initials Stage Description Hours Amount 08/14/20 SEM PHASE1 Draft email to Greater New York 0.50 222.50 Councils to advise of their new lawsuits and to include summaries of the same from the New York litigation tracking spreadsheet and to seek information related to said cases. 08/14/20 SEM PHASE1 Email from New York defense 0.10 44.50 counsel advising of measures taken to accept expanded assignment of additional new abuse lawsuits. 08/14/20 SEM PHASE1 Email to New York defense counsel, 0.20 89.00 Wiggin and Dana, to assign thirty-one (31) new lawsuits filed against the Greater New York Councils and direct to enter appearances and file Notices of BSA Bankruptcy stay. 08/14/20 KAD PHASE1 Email exchange with Anna Kutz 0.10 19.00 regarding service of process on Longhouse Council with Daniel Davis lawsuit and updating Riskonnect with same. 08/14/20 KAD PHASE1 Update Daniel Davis claim record in 0.10 19.00 Riskonnect to reflect completion of service of process on Longhouse Council. 08/14/20 KAD PHASE1 Review notice of hearing regarding 0.10 19.00 plaintiff's motion to compel discovery and email from Kathleen Russell regarding same. 08/14/20 KAD PHASE1 Update Michael Block claim record in 0.10 19.00 Riskonnect to reflect completion of service of process on Seneca Waterways Council. 08/14/20 KAD PHASE1 Update Michael Botsford claim record 0.10 19.00 in Riskonnect to reflect completion of service of process on Seneca Waterways Council. 08/14/20 KAD PHASE1 Prepare weekly new claims report. 3.40 646.00 08/14/20 KAD PHASE1 Email Sidley Austin, Alvarez Marsal, 0.10 19.00 BSA and Monica Blacker regarding weekly new abuse claims report. Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 29 of 74
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Date Initials Stage Description Hours Amount 08/14/20 KAD PHASE1 Email exchange with William Curtain 0.10 19.00 regarding cases to add to Schedule 1 on the next update. 08/14/20 KAD PHASE1 Review email from Anna Kutz 0.10 19.00 regarding service of process on Seneca Waterways Council with Michael Block lawsuit and updating Riskonnect with same. 08/14/20 KAD PHASE1 Review email from Anna Kutz 0.10 19.00 regarding service of process on Seneca Waterways Council with Michael Botsford lawsuit and updating Riskonnect with same. 08/14/20 KAD PHASE1 Review emails, rosters and other 0.30 57.00 documents received from the Greater New York Councils in connection with various newly filed New York lawsuits. 08/17/20 BAG PHASE1 Review email status update received 0.20 128.00 from defense counsel and Powers v BSA (PA) and attention to same. 08/17/20 BAG PHASE1 Review Media coverage of new 0.20 128.00 claims in Arkansas. 08/17/20 BAG PHASE1 Review and respond to Paul 0.20 128.00 Needham at Aspen Insurance regarding claim status in Jane Doe v BSA (MI). 08/17/20 BAG PHASE1 Review and analyze complaints chart 1.00 640.00 for all New York cases and internal communications with Sean Manning and Kelci Davis regarding same. 08/17/20 SEM PHASE1 Email exchange with Pennsylvania 0.30 133.50 defense counsel regarding service of the Powers case on the BSA and to review and approve of the filing of the proposed Notice of stay of litigation. 08/17/20 SEM PHASE1 Review news article from Arkansas 0.30 133.50 regarding three Abused in Scouting claimants and general "AIS" claims information and forward same to BSA for review. Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 30 of 74
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Date Initials Stage Description Hours Amount 08/17/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 the Douglas Burr case filed in New Jersey. 08/17/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 the David Walsh case filed in New Jersey. 08/17/20 SEM PHASE1 Review New Jersey lawsuit filed for 0.80 356.00 McVey, Sheerer, Burr and Walsh for individual claim information to follow- up on with the affected local councils. 08/17/20 SEM PHASE1 Email to affected local councils 0.40 178.00 related to New Jersey lawsuit filed for McVey, Sheerer, Burr and Walsh with claim details and request for follow-up on requests for information. 08/17/20 SEM PHASE1 Review information from BSA 0.20 89.00 regarding Abused in Scouting sending Sidley a new spreadsheet with 10,000 alleged claimants and discuss obtaining the same. 08/17/20 SEM PHASE1 Email from Westark Council with 0.30 133.50 information and records related to the McVey lawsuit in New Jersey, review and forward same to BSA. 08/17/20 SEM PHASE1 Review Gary Stanton lawsuit in New 0.40 178.00 York to collect information to send to Philmont in search of records and information related to the same. 08/17/20 SEM PHASE1 Email to BSA seeking point of contact 0.10 44.50 at Philmont for records search matters. 08/17/20 SEM PHASE1 Emails to New York defense counsel 0.80 356.00 with additional new lawsuit assignments and directions on the same. 08/17/20 SEM PHASE1 Review email with information and 0.40 178.00 documents from the Greater New York Councils related to several of the newly filed lawsuits against the council and forward same to BSA. 08/17/20 SEM PHASE1 Review weekly new claims report 0.10 44.50 Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 31 of 74
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Date Initials Stage Description Hours Amount from last week to ensure all new claims have been accounted for, tracked, and are being investigated. 08/17/20 SEM PHASE1 Draft emails to New York local 1.80 801.00 councils with notices of additional new lawsuits filed against them and requests for information related to the same. 08/17/20 SEM PHASE1 Email to New York defense counsel 0.30 133.50 with assignment of Twin Rivers Council lawsuits and background on the same. 08/17/20 SEM PHASE1 Email from BSA with Philmont contact 0.20 89.00 information to seek records related to new lawsuit filed in New York alleging abuse there and send request for the same to Philmont. 08/17/20 SEM PHASE1 Email from Theodore Roosevelt 0.30 133.50 Council in New York with notice of service of process in the JA-005 DOE case, review same and forward to defense counsel for handling. 08/17/20 SEM PHASE1 Email from Philmont regarding 0.10 44.50 request for records and information and processing of the same. 08/17/20 SEM PHASE1 Email exchange with New Mexico 0.20 89.00 defense counsel regarding request from Plaintiff's counsel in the John Doe (NM) case seeking BSA internal file for Richard Lucero. 08/17/20 SEM PHASE1 Review several news articles by 0.20 89.00 Oppenheim Law Firm seeking to collect new abuse victims and email same to BSA for alert. 08/17/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding the Complaint filed by Douglas Burr. 08/17/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding the Complaint filed by David Walsh. 08/17/20 KAD PHASE1 Review Arkansas Online news article 0.20 38.00 Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 32 of 74
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Date Initials Stage Description Hours Amount regarding three Arkansans story of alleged abuse. 08/17/20 KAD PHASE1 Review Chatter from Jennifer Nichols 0.10 19.00 regarding MI, IPs, and MI contacts created in connection with the lawsuit filed by Gary Stanton. 08/17/20 KAD PHASE1 Review email and documents from 0.20 38.00 Westark Area Council regarding the lawsuit filed by Kelly McVey. 08/17/20 KAD PHASE1 Email exchange with Anna Kutz 0.10 19.00 regarding dismissal of John Doe N.C. lawsuit and entering same in Riskonnect. 08/18/20 BAG PHASE1 Review multiple complaints filed by 0.50 320.00 the Pfau Cochran firm that do not name a scouting entity as a defendant. 08/18/20 BAG PHASE1 Email to Bill Curtin and Mike Andolina 0.10 64.00 at Sidley Austin regarding Pfau Chochran complaints. 08/18/20 BAG PHASE1 Review and respond to email from 0.10 64.00 Anna Kutz regarding Washing DC lawsuit. 08/18/20 BAG PHASE1 Internal team meeting with Kelci 2.50 1,600.00 Davis and Sean Manning to review and assess complaints filed during the week of August 17 and work on assessments of the complaints. 08/18/20 SEM PHASE1 Email from Hawaii defense counsel 0.10 44.50 with updated information related to John Roe Numbers 1 through 8 and review same. 08/18/20 SEM PHASE1 Review additional new cases filed 0.40 178.00 against chartered organizations only and not BSA or a local council. 08/18/20 SEM PHASE1 Follow-up email to Greater New York 0.20 89.00 Councils regarding confirmation of chartered organization defendants in new lawsuits without a BSA entity named, and revise to include new Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 33 of 74
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Date Initials Stage Description Hours Amount entities. 08/18/20 SEM PHASE1 Emails to New York defense firms to 0.30 133.50 assign additional cases not assigned initially. 08/18/20 SEM PHASE1 Telephone call with Greater New 0.10 44.50 York Councils to discuss research project related to old chartered organizations sued without a BSA entity. 08/18/20 SEM PHASE1 Review information related to 22 new 0.30 133.50 cases filed in New York this week and how to track those with common styles. 08/18/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 service of process on BSA National with new lawsuit filed in New York for JMRCPC Doe. 08/18/20 SEM PHASE1 Review new JMRCPC Doe lawsuit 0.50 222.50 filed in New York and summarize same for adding to the New York litigation tracking chart and sending to the Hudson Valley Council. 08/18/20 SEM PHASE1 Review BSA internal file for Richard 0.40 178.00 Roll, alleged perpetrator in the new JMRCPC Doe case filed in New York to assist in obtaining information related to Plaintiff's claims. 08/18/20 SEM PHASE1 Email to Hudson Valley Council with 0.20 89.00 new JMRCPC Doe lawsuit and request for information related to the same. 08/18/20 SEM PHASE1 Email to New York defense Counsel. 0.20 89.00 08/18/20 SEM PHASE1 Draft emails to New York local 0.50 222.50 councils that cover areas where new lawsuits have been filed naming only alleged chartered organizations in order to confirm defendants were in fact chartered organizations at the time of the alleged abuse. 08/18/20 SEM PHASE1 Email to Sidley with update on 0.20 89.00 research to confirm named Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 34 of 74
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Date Initials Stage Description Hours Amount defendants in non-BSA entity lawsuits are in fact chartered organizations. 08/18/20 SEM PHASE1 Review summary of deposition of 0.10 44.50 Officer Johnny Burgraff taken in the Kentucky LMPD Explorer case provided by local defense counsel. 08/18/20 SEM PHASE1 Email exchange with New Mexico 0.20 89.00 defense counsel seeking a copy of the proposed protective order to possibly be entered in the John Doe (NM) case. 08/18/20 SEM PHASE1 Review report from the hearing on 0.10 44.50 plaintiff’s motion to compel discovery of Defendant Richard Lucero prepared by New Mexico defense counsel. 08/18/20 SEM PHASE1 Email discussion with BSA and Sidley 0.40 178.00 regarding potential production of Richard Lucero BSA internal file in the John Does (NM) lawsuit in New Mexico. 08/18/20 SEM PHASE1 Email to Sidley with proposed 0.20 89.00 protective order to enter in the John Doe (NM) case should we choose to produce the Richard Lucero BSA internal file with a discussion of the changes to the same. 08/18/20 SEM PHASE1 Begin reviewing 22 new lawsuits filed 0.50 222.50 in New York and summarize same for the New York litigation tracking chart and for sending to affected local councils for search of records and information. 08/18/20 SEM PHASE1 Email from BSA advising of service or 0.20 89.00 process in the George Hamann lawsuit in New York against the Seneca Waterways Council and forward notice to local defense counsel. 08/18/20 SEM PHASE1 Review issues of Plaintiff's improperly 0.10 44.50 filing new lawsuits in New York when proper venue and jurisdiction is Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 35 of 74
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Date Initials Stage Description Hours Amount California and New Jersey. 08/18/20 SEM PHASE1 Email from Twin Rivers Council 0.10 44.50 seeking a complete list of all claims and cases pending against them. 08/18/20 SEM PHASE1 Email from Longhouse Council 0.20 89.00 alerting to service of process in the Jeffries, Jeffries, Hale and Egan cases and forward same to BSA. 08/18/20 SEM PHASE1 Gather information related to the 0.30 133.50 Jeffries, Jeffries, Hale and Egan lawsuits filed in New York and served on the Longhouse Council today and send same to local defense counsel. 08/18/20 SEM PHASE1 Email from Theodore Roosevelt 0.20 89.00 Council with documents and information in response to the Jeffrey Weems lawsuit investigation. 08/18/20 SEM PHASE1 Email from Longhouse Council with 0.20 89.00 information and documents related to the John Doe 28 J.N. lawsuit, review same and forward to BSA. 08/18/20 SEM PHASE1 Email from Longhouse Council with 0.20 89.00 information and documents related to the Richard Bacon lawsuit, review same and forward to BSA. 08/18/20 SEM PHASE1 Email from Longhouse Council with 0.20 89.00 information and documents related to the John Doe 41 RA lawsuit, review same and forward to BSA. 08/18/20 SEM PHASE1 Email to New York defense counsel 0.40 178.00 requesting they follow-up with Plaintiff's counsel in the John Doe 41 R.A. case given the typographical errors noted in several lawsuits and clarification of the abuse date and provide background data related to the same. 08/18/20 SEM PHASE1 Begin review of lawsuits filed in New 1.00 445.00 York for JMNYC1, Hickman, and John Doe to determine if they have been improperly filed from their Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 36 of 74
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Date Initials Stage Description Hours Amount proper New Jersey and California jurisdictions. 08/18/20 SEM PHASE1 Telephone call from Hudson Valley 0.20 89.00 Council to advise of service of process in the JMRCPC case and notify BSA and defense counsel of the same. 08/18/20 SEM PHASE1 Conference call with Sidley regarding 0.40 178.00 potential production of Richard Lucero BSA internal file in New Mexico John Doe case. 08/18/20 SEM PHASE1 Email exchange with BSA regarding 0.30 133.50 activity and plaintiffs in the Washington DC case. 08/18/20 SEM PHASE1 Email exchange with BSA regarding 0.30 133.50 notice of news media related to the newly filed Robert Hickman case filed in New York and review exchange of information between BSA and the Monmouth Council about the same and forward information about the perpetrator to Membership Standards. 08/18/20 KAD PHASE1 Email exchange with Anna Kutz 0.10 19.00 regarding the number of New York lawsuits to enter into Riskonnect. 08/18/20 KAD PHASE1 Email exchange with Anna Kutz 0.10 19.00 regarding entering John Doe N.C. case. 08/18/20 KAD PHASE1 Email exchange with William Curtain 0.10 19.00 regarding lawsuits to add during next update to Schedule 1. 08/18/20 KAD PHASE1 Analyze and identify new cases sent 0.30 57.00 by PCVA group to Sidley Austin. 08/18/20 KAD PHASE1 Email exchange with Nicole 0.10 19.00 Liberatore regarding AB 420 Doe lawsuit. 08/18/20 KAD PHASE1 Review email from Anna Kutz 0.10 19.00 regarding new lawsuit filed by JMRCPC Doe. Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 37 of 74
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Date Initials Stage Description Hours Amount 08/18/20 KAD PHASE1 Search BSA's internal files for alleged 0.20 38.00 perpetrator named in new JMRCPC Doe lawsuit. 08/18/20 KAD PHASE1 Analyze lawsuit filed by John Doe 34 0.20 38.00 C.P. in preparation of entering same in Riskonnect. 08/18/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by John Doe 34 C.P. 08/18/20 KAD PHASE1 Analyze lawsuit filed by AB 401 Doe 0.20 38.00 in preparation of entering same in Riskonnect. 08/18/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by AB 401 Doe. 08/18/20 KAD PHASE1 Review email from Cassandra 0.10 19.00 Malone regarding status update on the hearing regarding plaintiff's Motion to Compel. 08/18/20 KAD PHASE1 Email exchange with Anna Kutz 0.10 19.00 regarding service of process completed on Seneca Waterways Council in connection with the George Hamann lawsuit. 08/18/20 KAD PHASE1 Update George Hamann claim record 0.10 19.00 in Riskonnect to reflect completion of service of process on Seneca Waterways Council per Anna Kutz request. 08/18/20 KAD PHASE1 Review email from Adrian Lavarias 0.10 19.00 regarding John Roes 1-8 dates of birth. 08/18/20 KAD PHASE1 Update claim record in Riskonnect 0.20 38.00 with corrected dates of birth for John Roes 1-3 and chatter Jennifer Nichols regarding same. 08/19/20 BAG PHASE1 Review email exchange with Scout 0.20 128.00 executive regarding Washington DC Complaint pertaining to Arkansas Councils and attention to same. 08/19/20 BAG PHASE1 Review draft status report in Delarego 0.20 128.00 SP v BSA and exchange email with Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 38 of 74
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Date Initials Stage Description Hours Amount defense counsel regarding same. 08/19/20 BAG PHASE1 Continue review and analysis of new 2.50 1,600.00 complaints filed. 08/19/20 BAG PHASE1 Telephone conference with attorney 0.20 128.00 Paul Mones regarding bankruptcy status. 08/19/20 SEM PHASE1 Email exchange with Massachusetts 0.20 89.00 defense counsel regarding the status report due to the court in the DiLorenzo case, review and approve same. 08/19/20 SEM PHASE1 Email exchange with Suffolk County 0.20 89.00 Council in New York to advise of dismissal of John Doe N.C. case as he is the same Plaintiff as Nelson Carlo. 08/19/20 SEM PHASE1 Research Arkansas AIS claims for 1.00 445.00 potential identity of individuals identified in the Arkansas Gazette news article at the request of the Quapaw Council and respond to request for information on the same. 08/19/20 SEM PHASE1 Email from the Hudson Valley Council 0.20 89.00 in New York with documents served on them yesterday in the JMRCPC lawsuit and forward same to local defense counsel. 08/19/20 SEM PHASE1 Email exchange with Crossroads of 0.20 89.00 America Council in Indiana advising they have no information related to the William Scheerer case filed in New Jersey. 08/19/20 SEM PHASE1 Complete reviewing new lawsuits 1.00 445.00 filed in New York that appear to be improperly filed out of their proper jurisdiction of California and New Jersey. 08/19/20 SEM PHASE1 Email from New York defense 0.10 44.50 counsel regarding process of working through conflicts checks on all newly assigned Twin Rivers Council cases. Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 39 of 74
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Date Initials Stage Description Hours Amount 08/19/20 SEM PHASE1 Email exchange with Suffolk County 0.20 89.00 Council regarding service of process in the William Halliday case. 08/19/20 SEM PHASE1 Email exchange with Suffolk County 0.30 133.50 Council and BSA to review of process of preparing and sending them a complete list of all pending claims and lawsuits. 08/19/20 SEM PHASE1 Determine proper New York defense 0.20 89.00 counsel and alert them to the newly served William Halliday lawsuit. 08/19/20 SEM PHASE1 Email exchange with Monmouth 0.20 89.00 Council regarding the total number of new lawsuits involving Forestburg Scout Reservation. 08/19/20 SEM PHASE1 Draft emails to Patriots Path Council 0.60 267.00 and Monmouth Council - both located in New Jersey - regarding new lawsuits filed in New York to collect information related to improper filing and to discuss background of the cases at issue. 08/19/20 SEM PHASE1 Email exchange with Sidley regarding 0.20 89.00 update on decision of action to take on cases filed only against chartered organizations without a BSA entity. 08/19/20 SEM PHASE1 Email from BSA alerting of service of 0.20 89.00 process of the JMRCPC lawsuit on BSA National and advise local defense counsel of the same. 08/19/20 SEM PHASE1 Email from Hudson Valley Council in 0.20 89.00 New York advising they were served in the Robert Harrington lawsuit today and notify local defense counsel and BSA National. 08/19/20 SEM PHASE1 Email exchange with Suffolk County 0.30 133.50 Council regarding documents related to the William Halliday case, review same and send to BSA. 08/19/20 SEM PHASE1 Email exchange with Wiggin and 0.30 133.50 Dana, New York local defense Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 40 of 74
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Date Initials Stage Description Hours Amount counsel regarding clarification of all 130 lawsuits they have been assigned and collect data to send to them for that purpose. 08/19/20 SEM PHASE1 Email from Suffolk County Council in 0.30 133.50 New York with documents and information related to the Robert Pisano lawsuit, review and forward same to BSA. 08/19/20 SEM PHASE1 Email exchange with Quapaw Area 0.20 89.00 Council regarding claims information and providing data related to discrepancies therein. 08/19/20 SEM PHASE1 Receive and review 14 emails from 0.80 356.00 Longhouse Council in New York related to seven (7) new lawsuits filed against the council, with information and documents related thereto, review and forward same to BSA. 08/19/20 SEM PHASE1 Email exchange with Quapaw Area 0.20 89.00 Council regarding information related to Plaintiff Doe 5 claim in the multi- plaintiff Washington D.C. lawsuit and discussion of discrepancies in his claim. 08/19/20 SEM PHASE1 Draft a memorandum to the file 0.50 222.50 pertaining to Plaintiff Doe 5 in the multi-plaintiff Washington D.C. case regarding information provided by the Quapaw Area Council. 08/19/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding the lawsuit filed by AB 401 Doe and the status of the Local Council's record search. 08/19/20 KAD PHASE1 Review email from Nicole Liberatore 0.10 19.00 regarding notices of second stipulation and agreed order filed in newly filed New York cases. 08/19/20 KAD PHASE1 Review Troop charters from Local 0.10 19.00 Council and email from Chris Coscia regarding same in connection with the Jeffrey Weems lawsuit. Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 41 of 74
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Date Initials Stage Description Hours Amount 08/19/20 KAD PHASE1 Review email from Helen Forward 0.10 19.00 regarding the completion of process of service on Longhouse Council in four New York cases. 08/19/20 KAD PHASE1 Update claim record in Riskonnect for 0.20 38.00 four New York cases to reflect completion of process of service on Longhouse Council. 08/19/20 KAD PHASE1 Analyze lawsuit filed by Donald 0.20 38.00 Gordon in preparation of entering same in Riskonnect. 08/19/20 KAD PHASE1 Analyze lawsuit filed by Jeff Moleski 0.20 38.00 in preparation of entering same in Riskonnect. 08/19/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by Donald Gordon. 08/19/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by Jeff Moleski. 08/19/20 KAD PHASE1 Analyze lawsuit filed by Richard 0.20 38.00 Hodges in preparation of entering same in Riskonnect. 08/19/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by Richard Hodges. 08/19/20 KAD PHASE1 Review email from Ryan DiBernardo 0.10 19.00 regarding completion of service of process on Suffolk County Council in connection with the lawsuit filed by William Halliday. 08/19/20 KAD PHASE1 Update William Halliday claim record 0.10 19.00 in Riskonnect to reflect completion of service of process upon Suffolk County Council. 08/19/20 KAD PHASE1 Receive and review request from 0.10 19.00 Suffolk County Council for claims report and coordinate with Sean Manning regarding same. 08/19/20 KAD PHASE1 Search BSA's internal files for alleged 0.40 76.00 perpetrators named in Robert Hickman and John Doe (20201143) lawsuits. Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 42 of 74
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Date Initials Stage Description Hours Amount 08/19/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding the lawsuit filed by AB 400 Doe. 08/19/20 KAD PHASE1 Analyze lawsuit filed by AB 402 Doe 0.20 38.00 in preparation of entering same in Riskonnect. 08/19/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by AB 402 Doe. 08/19/20 KAD PHASE1 Review email from William Curtain 0.10 19.00 regarding further abuse actions. 08/19/20 KAD PHASE1 Review email from Anna Kutz 0.10 19.00 regarding completion of service of process on BSA National in JMRCP Doe case. 08/20/20 BAG PHASE1 Review email and attachments 0.20 128.00 received from Anna Kutz regarding the Kirch v Baden Powell Council matter and internal communications with Sean Manning regarding same. 08/20/20 BAG PHASE1 Review email and Motion to Dismiss 0.30 192.00 received from defense counsel in Lawson v. BSA. 08/20/20 BAG PHASE1 Review and respond to email from 0.10 64.00 Adrian Azer regarding perpetrator's request for coverage. 08/20/20 BAG PHASE1 Review email update from defense 0.10 64.00 counsel in O'Connell v Northern New Jersey Council. 08/20/20 BAG PHASE1 Internal team meeting regarding 0.50 320.00 claims. 08/20/20 BAG PHASE1 Continue analysis of claims received 2.00 1,280.00 during the week of August 17. 08/20/20 SEM PHASE1 Review new lawsuit filed in New York 0.40 178.00 for Robert Zilliox and summarize same for the Greater Niagara Frontier Council. 08/20/20 SEM PHASE1 Email from Greater New York 0.60 267.00 Councils with documents and information related to new lawsuits Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 43 of 74
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Date Initials Stage Description Hours Amount filed against the council, review same and forward to BSA. 08/20/20 SEM PHASE1 Email exchange with Baden-Powell 0.20 89.00 Council regarding service of process in the Martin Kirch case. 08/20/20 SEM PHASE1 Review co-defendant Estate of Gene 0.80 356.00 Bobo's 39 page Motion to Dismiss in the Georgia lawsuit filed by Plaintiff Robert William Lawson's received from defense counsel. 08/20/20 SEM PHASE1 Email exchange with Georgia 0.20 89.00 defense counsel regarding potential ruling from the Georgia Court of Appeals decision in Phillip Doe v. Archdiocese of Atlanta and effect on pending BSA cases including Lawson. 08/20/20 SEM PHASE1 Research history of Baden-Powell 0.10 44.50 Council in New York and relationship to the Susquenango Council to explain defendant naming and service matters in the Kirch case. 08/20/20 SEM PHASE1 Email to New York defense counsel, 0.20 89.00 Melick & Porter, to advise of service of process on the the Baden-Powell and Susquenango Councils and discuss history of councils for use in representation of now defunct Susquenango Council. 08/20/20 SEM PHASE1 Begin review of new lawsuits filed in 3.50 1,557.50 New York last week and summarize the same for the affected local councils and for requests for investigative information. 08/20/20 SEM PHASE1 Email from Theodore Roosevelt 0.10 44.50 Council in New York advising they have no information related to the alleged chartered organization at issue in the M.D. case where no BSA entity has been named. 08/20/20 SEM PHASE1 Email exchange with BSA regarding 0.10 44.50 notice from Leatherstocking Council Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 44 of 74
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Date Initials Stage Description Hours Amount of service of process in the Christian Debaun case and need to reach out to the Scout Executive regarding the same. 08/20/20 SEM PHASE1 Review newly served Christian 0.50 222.50 Debaun case in New York and email Leatherstocking Council regarding action on the same. 08/20/20 SEM PHASE1 Review email from Everest Insurance 0.10 44.50 seeking an update on claims activity or if all claims remain stayed. 08/20/20 SEM PHASE1 Email exchange with New Jersey 0.20 89.00 defense counsel regarding perpetrator in the Pedro Lopez case filing a Motion to Dismiss as never being a registered Scout leader. 08/20/20 SEM PHASE1 Email exchange with New York 0.20 89.00 defense counsel regarding appearance and Notice filings for alleged chartered organizations in the JA-081 DOE case. 08/20/20 SEM PHASE1 Email from New Mexico defense 0.20 89.00 counsel with Plaintiff John Doe (NM) Request for Presentment Hearing on his Motion to Compel against Defendant Richard Lucero and review the same. 08/20/20 SEM PHASE1 Email from New York defense 0.20 89.00 counsel with several filed Notices of Second Consent Order in Twin Rivers Council cases and review same. 08/20/20 KAD PHASE1 Review news article regarding 0.10 19.00 pressure on Local Councils in sex- abuse lawsuits. 08/20/20 KAD PHASE1 Analyze information and documents 0.30 57.00 received from Greater New York Council in connection with various newly filed lawsuits. 08/20/20 KAD PHASE1 Analyze multiple emails and 0.50 95.00 documents received from the Longhouse Council in connection with Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 45 of 74
Page 44 09/15/20 Bill No. 90275792 047657.000013-BAG
Date Initials Stage Description Hours Amount various newly filed New York lawsuits. 08/20/20 KAD PHASE1 Review email and documentation 0.20 38.00 from Suffolk County Council regarding Robert Pisano lawsuit. 08/20/20 KAD PHASE1 Update Robert Harrington claim 0.10 19.00 record in Riskonnect to reflect completion of service of process on Hudson Valley Council. 08/20/20 KAD PHASE1 Analyze lawsuit filed by AB 403 Doe 0.20 38.00 in preparation of entering same in Riskonnect. 08/20/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by AB 403 Doe. 08/20/20 KAD PHASE1 Analyze lawsuit filed by AB 404 Doe 0.20 38.00 in preparation of entering same in Riskonnect. 08/20/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by AB 404 Doe. 08/20/20 KAD PHASE1 Review email from Anna Kutz 0.10 19.00 regarding service of process on Baden-Powell Council in connection with the Martin Kirch lawsuit. 08/20/20 KAD PHASE1 Analyze lawsuit filed by AB 405 Doe 0.20 38.00 in preparation of entering same in Riskonnect. 08/20/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by AB 405 Doe. 08/20/20 KAD PHASE1 Analyze lawsuit filed by AB 406 Doe 0.20 38.00 in preparation of entering same in Riskonnect. 08/20/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by AB 406 Doe. 08/20/20 KAD PHASE1 Analyze lawsuit filed by AB 407 Doe 0.20 38.00 in preparation of entering same in Riskonnect. 08/20/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by AB 407 Doe. Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 46 of 74
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Date Initials Stage Description Hours Amount 08/20/20 KAD PHASE1 Review email from Anna Kutz 0.10 19.00 regarding service of process on Iroquois Trail Council in connection with the lawsuit filed by Christian Debaun. 08/20/20 KAD PHASE1 Internal team meeting to discuss new 0.30 57.00 claims and overall status of process same. 08/20/20 KAD PHASE1 Email exchange with Robyn Jungers 0.10 19.00 regarding Jorge Fuentes complaint. 08/21/20 BAG PHASE1 Review email from defense counsel 0.20 128.00 regarding additional motions filed in Jane Doe v Town of Cascade Township (MI)and email to Mike Andolina regarding same. 08/21/20 SEM PHASE1 Review article from New York Injury 0.10 44.50 Law News "BSA Local Councils Under Pressure in Sex-Abuse Lawsuits". 08/21/20 SEM PHASE1 Review email from New Jersey 0.40 178.00 defense counsel regarding co- defendant Archdiocese of Newark's motion to transfer venue in the O'Connell v. Northern New Jersey Council and related pleadings and review the same. 08/21/20 SEM PHASE1 Complete review of new lawsuits filed 1.00 445.00 in New York, add to New York litigation tracking spreadsheet, summarize said cases and prepare to send to affected local councils with requests for information about the same. 08/21/20 SEM PHASE1 Draft emails to New York local 1.50 667.50 councils with copies of new lawsuits and summaries of the same to put them on notice of the same and to seek information and records related to the same. 08/21/20 SEM PHASE1 Emails to Greater New York Councils 0.30 133.50 with litigation tracking spreadsheet and summaries of new lawsuits filed Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 47 of 74
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Date Initials Stage Description Hours Amount against this council this week. 08/21/20 SEM PHASE1 Emails to New York defense counsel 0.50 222.50 firms with assignments of new lawsuits filed in New York. 08/21/20 SEM PHASE1 Email from Allegheny Highlands 0.20 89.00 Council with documents and information related to Eric Anderson lawsuit and review same. 08/21/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 incorrect date of abuse found in Ronald Kim and Chris Hurley lawsuits and the handling of the same. 08/21/20 SEM PHASE1 Review weekly new claims report 0.10 44.50 prepared by Kelci Davis to ensure all newly filed cases have been processed and sent to BSA.. 08/21/20 SEM PHASE1 Emails to California local councils 0.50 222.50 with information related to the JMNYC1 lawsuit filed in New York this last week for research and notice of the same. 08/21/20 SEM PHASE1 Email exchange with the Greater 0.20 89.00 Niagara Frontier Council regarding search for information related to newest New York lawsuits. 08/21/20 SEM PHASE1 Email exchange with Michigan 0.20 89.00 defense counsel regarding discovery dispute motions filed in the Jane Doe v. Cascade Township case and continued violation of the BSA bankruptcy stay. 08/21/20 SEM PHASE1 Email from Lewis Brisbois law firm in 0.10 44.50 New York regarding assignment of newly filed lawsuits to their firm. 08/21/20 SEM PHASE1 Email from New York defense 0.20 89.00 counsel with copies of filed Notices of Bankruptcy Stay in several newly filed lawsuits and review same. 08/21/20 SEM PHASE1 Review number of new lawsuits filed 0.10 44.50 by certain Plaintiff's law firms relative Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 48 of 74
Page 47 09/15/20 Bill No. 90275792 047657.000013-BAG
Date Initials Stage Description Hours Amount to additional newly filed actions. 08/21/20 SEM PHASE1 Email from California defense 0.20 89.00 counsel with Notices of BSA Bankruptcy Stay filed in several new lawsuits there and review the same. 08/21/20 SEM PHASE1 Email exchange with Iroquois Trail 0.20 89.00 Council in New York regarding insight into new lawsuits filed against the council. 08/21/20 SEM PHASE1 Email to Sidley with information and 0.10 44.50 pleadings related to Jane Doe v. Cascade Township discovery motion matter. 08/21/20 SEM PHASE1 Review email from BSA to insurance 0.10 44.50 carriers with updated claims list. 08/21/20 SEM PHASE1 Email exchange with New York 0.20 89.00 defense counsel regarding handling of CHUBB insured years of abuse. 08/21/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding lawsuit filed by Martin Kirch. 08/21/20 KAD PHASE1 Email exchange with Kathleen 0.10 19.00 Russell regarding Plaintiff's Request for Presentment Hearing. 08/21/20 KAD PHASE1 Email Sidley Austin, Alvarez Marsal, 0.10 19.00 BSA and Monica Blacker regarding weekly new abuse claims report. 08/21/20 KAD PHASE1 Prepare weekly new claims report. 3.90 741.00 08/21/20 KAD PHASE1 Review email from Robyn Jungers 0.10 19.00 regarding BSA's updated notice to the carriers in connection with the lawsuit filed by Jorge Fuentes. 08/21/20 KAD PHASE1 Email Anna Kutz and Robyn Jungers 0.20 38.00 regarding incorrect dates of abuse alleged in New York lawsuits and entering same in Riskonnect. 08/21/20 KAD PHASE1 Review Chatter from Robyn Jungers 0.10 19.00 regarding plaintiff's contact record in connection with the lawsuits filed by Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 49 of 74
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Date Initials Stage Description Hours Amount John Bobeck. 08/21/20 KAD PHASE1 Review information and documents 0.20 38.00 received from Greater New York Councils in connection with various recently filed lawsuits in New York. 08/21/20 KAD PHASE1 Calculate the number of claims filed 0.20 38.00 by the Marsh Law Firm, Pfau Cochran and Faraci Lange, LLP. 08/21/20 KAD PHASE1 Search BSA's internal files for 65 2.40 456.00 alleged perpetrators named in newly filed New York lawsuits. 08/24/20 BAG PHASE1 Review complaints filed McDonald, 0.50 320.00 Howard, Perry and Forde matters in New York and attention to service information council assignments. 08/24/20 BAG PHASE1 Review email from defense counsel 0.30 192.00 in pending cases against the Twin Rivers Council in New York and attention to filing of Bankruptcy Stay Notices and assignment of counsel. 08/24/20 BAG PHASE1 Exchange email with Oregon defense 0.30 192.00 counsel regarding potential disclosure information from Attorney Gilion Dumas's office and attention to same. 08/24/20 BAG PHASE1 Review case management plan 0.50 320.00 updates received from defense counsel in the Kentucky Explorer cases. 08/24/20 BAG PHASE1 Review service information for cases 0.20 128.00 served on Five Rivers Council and internal communications with Sean Manning regarding same. 08/24/20 BAG PHASE1 Review complaints filed in the Temple 0.30 192.00 and Borbely matters in New York and attention to same. 08/24/20 BAG PHASE1 Review email from Heather Cambell 0.20 128.00 at Allianz Insurance regarding request for copies of complaints filed and internal communications with Kelci Davis regarding same. Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 50 of 74
Page 49 09/15/20 Bill No. 90275792 047657.000013-BAG
Date Initials Stage Description Hours Amount 08/24/20 BAG PHASE1 Review chart pertaining to charted 0.20 128.00 organizations in New York cases and internal communication with Sean Manning regarding same. 08/24/20 SEM PHASE1 Email from New York defense 0.20 89.00 counsel with Notice of Stay filed in John Doe 79 and review the same. 08/24/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 the BSA internal file for an alleged perpetrator in New York; John A. Duffy. 08/24/20 SEM PHASE1 Review an extensive email string 0.30 133.50 between BSA and Seneca Waterways Council in New York regarding perpetrator Alan Dean and further review unit rosters and documentation attached thereto. 08/24/20 SEM PHASE1 Email from Golden Gate Area Council 0.30 133.50 in California regarding information related to the JMNYC1 case filed in New York and email from BSA regarding the same. 08/24/20 SEM PHASE1 Email from Greater New York 0.80 356.00 Councils with information related to numerous newly filed lawsuits, review same, forward to BSA and update the New York litigation tracking spreadsheet with the same. 08/24/20 SEM PHASE1 Review information from local 0.50 222.50 councils related to lawsuits naming only alleged chartered organizations and not a BSA entity. 08/24/20 SEM PHASE1 Email exchange with Allianz 0.20 89.00 Insurance Company with copies of complaints requested by Company. 08/24/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 information related to alleged perpetrator in the JA-067 Doe case filed in New York and review the same. 08/24/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 51 of 74
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Date Initials Stage Description Hours Amount possible fishing email from Gilion Dumas. 08/24/20 SEM PHASE1 Email exchange with New York 0.20 89.00 defense counsel regarding clarification about BSA related entities to enter their appearance for. 08/24/20 SEM PHASE1 Email from BSA advising of service of 0.10 44.50 process in the Tom McDonald lawsuit filed in New York against the Seneca Waterways Council. 08/24/20 SEM PHASE1 Email from Seneca Waterways 0.10 44.50 Council in New York regarding additional new information related to the Tom McDonald case. 08/24/20 SEM PHASE1 Email from BSA advising of service of 0.10 44.50 process in the Norman Wolfe lawsuit filed in New York against the Seneca Waterways Council. 08/24/20 SEM PHASE1 Review information received in regard 0.30 133.50 to the Norman Wolfe lawsuit and discuss same with BSA. 08/24/20 SEM PHASE1 Email from BSA with notice of service 0.10 44.50 of process on the Five Rivers Council in New York with the Douglas Howard lawsuit. 08/24/20 SEM PHASE1 Email from BSA with notice of service 0.10 44.50 of process in the Darrel Forde case against the Westchester-Putnam Council in New York. 08/24/20 SEM PHASE1 Email from BSA with notice of service 0.10 44.50 of process on the Five Rivers Council in New York with the Daniel Perry lawsuit. 08/24/20 SEM PHASE1 Review all new lawsuits served today 0.40 178.00 and prepare to send notice of service of same to local New York defense counsel. 08/24/20 SEM PHASE1 Email exchange with Greater Niagara 0.20 89.00 Frontier Council regarding notice of newly filed lawsuit for John Suchocki. Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 52 of 74
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Date Initials Stage Description Hours Amount 08/24/20 SEM PHASE1 Review newly filed lawsuit for John 0.30 133.50 Suchocki filed against the Greater Niagara Frontier Council and summarize same for the New York litigation tracking spreadsheet. 08/24/20 SEM PHASE1 Review additional new lawsuits filed 0.60 267.00 last week in New York and summarize the same for the New York litigation tracking spreadsheet. 08/24/20 KAD PHASE1 Review email and documentation 0.20 38.00 from Greater New York Councils regarding John Doe 18 J.D. lawsuit. 08/24/20 KAD PHASE1 Analyze lawsuit filed by AB 408 Doe 0.20 38.00 in preparation of entering same in Riskonnect. 08/24/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by AB 408 Doe. 08/24/20 KAD PHASE1 Analyze lawsuit filed by AB 409 Doe 0.20 38.00 in preparation of entering same in Riskonnect. 08/24/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by AB 409 Doe. 08/24/20 KAD PHASE1 Review email from Anna Kutz 0.10 19.00 regarding completion of service of process on Seneca Waterways Council in connection with the Tom McDonald lawsuit. 08/24/20 KAD PHASE1 Analyze lawsuit filed by AB 412 Doe 0.20 38.00 in preparation of entering same in Riskonnect. 08/24/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by AB 412 Doe. 08/24/20 KAD PHASE1 Review email from Anna Kutz 0.10 19.00 regarding service of process on Seneca Waterways Council in connection with the Norman Wolfe lawsuit. 08/24/20 KAD PHASE1 Email Heather Campbell regarding 0.10 19.00 her request for copies of newly filed Complaints. Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 53 of 74
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Date Initials Stage Description Hours Amount 08/24/20 KAD PHASE1 Compile copies of Complaints 0.50 95.00 requested by Heather Campbell at Allianz. 08/24/20 KAD PHASE1 Email exchange with Nicole 0.10 19.00 Liberatore regarding notices of second stipulation and agreed order filed in 5 new, New York lawsuits. 08/24/20 KAD PHASE1 Analyze lawsuit filed by AB 415 Doe 0.20 38.00 in preparation of entering same in Riskonnect. 08/24/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by AB 415 Doe. 08/24/20 KAD PHASE1 Review email from Anna Kutz 0.10 19.00 regarding completion of service on Five Rivers Council in connection with the Douglas Howard lawsuit. 08/24/20 KAD PHASE1 Review email from Anna Kutz 0.10 19.00 regarding service of process on Westchester-Putnam Council in connection with the Darrel Forde lawsuit. 08/24/20 KAD PHASE1 Review email from Anna Kutz 0.10 19.00 regarding service of process on Five Rivers Council in connection with the Daniel Perry lawsuit. 08/25/20 BAG PHASE1 Review email from defense counsel 0.10 64.00 and notices filed in the Papas v BSA and Doe v BSA matters in New York. 08/25/20 BAG PHASE1 Review email from Anna Kutz and 0.20 128.00 complaint received in the John Doe matter in Missouri and attention to same. 08/25/20 BAG PHASE1 Review draft Consent Order in 0.20 128.00 O'Connell v Northern New Jersey Council and internal communications with Sean Manning regarding same. 08/25/20 BAG PHASE1 Review/analyze complaints received 2.50 1,600.00 during the week of August 23 and direct investigation regarding same. 08/25/20 BAG PHASE1 Internal team meeting to discuss 0.50 320.00 Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 54 of 74
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Date Initials Stage Description Hours Amount pending claims and status. 08/25/20 SEM PHASE1 Email from New Jersey defense 0.10 44.50 counsel regarding Plaintiff's proposed Stipulation and Consent Order to file in the John MM Doe case and proposed revisions. 08/25/20 SEM PHASE1 Review Plaintiff's proposed 0.50 222.50 Stipulation and Consent Order to file in the John MM Doe case in New Jersey and compare same to the BSA bankruptcy consent order and email defense counsel with input on the same. 08/25/20 SEM PHASE1 Email from New York defense 0.70 311.50 counsel with filed copies of BSA Notice of Bankruptcy Stay filed in their assigned cases. 08/25/20 SEM PHASE1 Emails from BSA with information and 0.30 133.50 pleadings related to the John Doe workers compensation case in Missouri, review same and forward to defense counsel. 08/25/20 SEM PHASE1 Email exchange with New Jersey 0.30 133.50 defense counsel regarding changes to Plaintiff's consent order in the O'Connell v. Northern New Jersey Council case and review and approve same. 08/25/20 SEM PHASE1 Email exchange with Kentucky 0.20 89.00 defense counsel in regard to further defense of LFL Explorer cases and desire to set a conference call to discuss same further. 08/25/20 SEM PHASE1 Review email from BSA to St. Louis 0.10 44.50 Council in regard to the John Doe Worker’s Compensation claim and providing notice to the Council insurance carrier regarding payment of fees on the same. 08/25/20 SEM PHASE1 Email exchange with Seneca 0.20 89.00 Waterways Council regarding Kim and Hurley complaint typo, real Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 55 of 74
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Date Initials Stage Description Hours Amount plaintiff names and the new John Doe 67 lawsuit filed against their council today. 08/25/20 SEM PHASE1 Email exchange with Iroquois Trail 0.20 89.00 Council regarding service of process in the Wagner and Debaun cases. 08/25/20 SEM PHASE1 Email from Iroquois Trail Council in 0.10 44.50 New York regarding ongoing research into the newly filed Michael Walton lawsuit. 08/25/20 SEM PHASE1 Review notice from BSA of 0.10 44.50 Westchester Putnam Council in New York regarding service of process in the S.C. case. 08/25/20 SEM PHASE1 Email from Seneca Waterways 0.10 44.50 Council with additional information related to research into newly filed lawsuits. 08/26/20 BAG PHASE1 Review complaints in New York 0.50 320.00 cases to be assigned to Melick and Porter and internal communications with Sean Manning regarding same. 08/26/20 BAG PHASE1 Review the most recent complaints 1.00 640.00 filed against the Greater New York Councils and related email exchanges regarding information pertaining to those cases. 08/26/20 BAG PHASE1 Review email from Anna Kutz 0.20 128.00 regarding Service of Process in the Lolya matter and attention to same. 08/26/20 BAG PHASE1 Review complaint in the Morales v 0.20 128.00 Rip Van Winkle Council matter and attention to same. 08/26/20 BAG PHASE1 Review media coverage regarding 0.20 128.00 BSA abuse claim notices and internal communications with Sean Manning regarding same. 08/26/20 BAG PHASE1 Review service information regarding 0.20 128.00 claim filed in New York against the Baden Powell council and attention to Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 56 of 74
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Date Initials Stage Description Hours Amount same. 08/26/20 BAG PHASE1 Review new complaint filed against 0.20 128.00 the Twin Rivers Council and attention to same. 08/26/20 BAG PHASE1 Review email and troop rosters and 0.30 192.00 other documents received from Scout Executive at Iroquois Trail Council and internal communications with Sean Manning regarding same. 08/26/20 SEM PHASE1 Review news articles related to BSA 0.30 133.50 abuse claims, council asset transfers, and BSA's motion to limit victim advertising, and send same to BSA and BSA team. 08/26/20 SEM PHASE1 Email from New York defense 0.20 89.00 counsel with request from chartered organization in the Borozoko case seeking a charter agreement from the council. 08/26/20 SEM PHASE1 Email to Greater Niagara Frontier 0.10 44.50 Council with request from chartered organization in the Boroszoko case seeking a copy of the 1967 charter agreement. 08/26/20 SEM PHASE1 Review service of process 0.20 89.00 information from the Iroquois Trail Council and send same to local New York defense counsel with direction for filing initial BSA pleadings. 08/26/20 SEM PHASE1 Email to local New York defense 0.20 89.00 counsel with notice of new lawsuits served on the Westchester Putnam Council and direction to file initial responsive pleadings. 08/26/20 SEM PHASE1 Email exchange with Greater Niagara 0.20 89.00 Frontier Council regarding difficulties in locating documents prior to 1985. 08/26/20 SEM PHASE1 Begin review of new lawsuits filed in 0.80 356.00 New York, summarize same for the New York litigation tracking spreadsheet and for request of Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 57 of 74
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Date Initials Stage Description Hours Amount information from the affected local councils. 08/26/20 SEM PHASE1 Email Baden Powell Council in New 0.20 89.00 York regarding confirmation of service of process in the Armstrong lawsuit. 08/26/20 SEM PHASE1 Email exchange with Iroquois Trails 0.30 133.50 Council regarding information and documents related to the Michael Walton lawsuit and review the same. 08/26/20 SEM PHASE1 Send emails to local councils with 0.40 178.00 new lawsuits filed against them with summaries of the same and requests for information. 08/26/20 SEM PHASE1 Emails to New York defense counsel 0.50 222.50 with assignment of newly filed lawsuits. 08/26/20 SEM PHASE1 Email to New York defense counsel 0.10 44.50 to advise of service of process on the Baden-Powell Council in the Armstrong case. 08/26/20 SEM PHASE1 Review Law 360 news article, "Boy 0.20 89.00 Scouts Seek To Curtail 'Misleading' Abuse Claim Notices" and send same to BSA and the BSA Team. 08/26/20 SEM PHASE1 Email from BSA with notice of service 0.20 89.00 of process on the Rip Van Winkle Council in New York in the Morales case and email the council to advise of the same. 08/26/20 SEM PHASE1 Review service of process documents 0.20 89.00 received by the Rip Van Winkle Council and send same to local New York defense counsel with direction to file standard BSA responsive pleadings. 08/26/20 SEM PHASE1 Email to Five Rivers Council to advise 0.10 44.50 that we received service of process papers and forwarded same to New York defense counsel. 08/26/20 SEM PHASE1 Email to Westchester-Putnam 0.10 44.50 Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 58 of 74
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Date Initials Stage Description Hours Amount Council to advise that service of process papers in the S.C. case were forwarded to New York defense counsel. 08/26/20 SEM PHASE1 Email from BSA with notice of service 0.20 89.00 of process on the Westchester- Putnam Council in the Michael Lolya case and email to the council to advise of the same. 08/26/20 SEM PHASE1 Review service of process papers in 0.20 89.00 the Michael Lolya in New York that were served on the Westchester- Putnam Council and forward same to defense counsel. 08/26/20 SEM PHASE1 Email from Greater New York 0.20 89.00 Councils with information and documents related to newly filed lawsuits and forward same to BSA. 08/26/20 SEM PHASE1 Review information and documents 0.40 178.00 received from the Greater New York Councils related to newly filed Lawsuits and update the New York litigation tracking spreadsheet with relevant facts. 08/26/20 SEM PHASE1 Email exchange with BSA related to 0.20 89.00 the Lolya case filed in New York. 08/26/20 SEM PHASE1 Email to Westchester-Putnam 0.10 44.50 Council related to information sought about the Michael Lolya case. 08/26/20 SEM PHASE1 Further email exchange with 0.20 89.00 Westchester-Putnam Council regarding the Michael Lolya case. 08/26/20 SEM PHASE1 Email exchange with Greater Niagara 0.20 89.00 Frontier Council regarding service of process in four (4) lawsuits. 08/26/20 KAD PHASE1 Review email from Anna Kutz 0.10 19.00 regarding completion of service of process on Westchester-Putnam Council in connection with the lawsuit filed by S.C. 08/26/20 KAD PHASE1 Update S.C. claims record in 0.10 19.00 Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 59 of 74
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Date Initials Stage Description Hours Amount Riskonnect to reflect completion of service of process on Westchester- Putnam Council. 08/26/20 KAD PHASE1 Review email from Anna Kutz 0.10 19.00 regarding lawsuit filed by John Doe 67 A.T. 08/26/20 KAD PHASE1 Review email and documents from 0.10 19.00 Anna Kutz regarding John Doe (MO) worker's compensation claim. 08/26/20 KAD PHASE1 Review USA Today newspaper article 0.10 19.00 regarding allegations of Boy Scouts trying to limit abuse survivors from coming forward by curbing ads. 08/26/20 KAD PHASE1 Analyze lawsuit filed by AB 418 Doe 0.20 38.00 in preparation of entering same in Riskonnect. 08/26/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by AB 418 Doe. 08/26/20 KAD PHASE1 Review email and rosters from 0.20 38.00 Iroquois Trail Council regarding lawsuit filed by Michael Walton. 08/27/20 BAG PHASE1 Review complaint and service 0.40 256.00 information regarding JMBXI Doe v BSA (NY) and attention to same. 08/27/20 BAG PHASE1 Review complaint and service 0.40 256.00 information in Timothy Singhel v BSA (NY) and attention to same. 08/27/20 SEM PHASE1 Review news article from Kansas City 0.30 133.50 Missouri regarding a new lawsuit filed by a 17 year-old girl claiming harassment at camp and forward same to BSA with input on the same. 08/27/20 SEM PHASE1 Email to Missouri defense counsel 0.10 44.50 regarding the new lawsuit filed against the Heart of America Council and request to obtain a copy of the complaint filed by a 17-year-old girl. 08/27/20 SEM PHASE1 Email to the Heart of America Council 0.10 44.50 to advise a copy of the 17-year-old girl lawsuit complaint would be sent Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 60 of 74
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Date Initials Stage Description Hours Amount once obtained and request for a conference call to discuss the same. 08/27/20 SEM PHASE1 Email to BSA Youth Protection in 0.10 44.50 regard to new Heart of America Council lawsuit. 08/27/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 new lawsuit filed against Suffolk County and Baden Powell Councils and processing of the same. 08/27/20 SEM PHASE1 Email with the Greater New York 0.10 44.50 Councils regarding service of process in the JMBXI Doe case. 08/27/20 SEM PHASE1 Email to New York defense counsel 0.10 44.50 advising of service of process on the Greater New York Councils in the JMBXI Doe case. 08/27/20 SEM PHASE1 Emails to New York defense counsel 0.30 133.50 with notice of service of lawsuits against the Greater Niagara Frontier Council and directions to file initial pleadings. 08/27/20 SEM PHASE1 Review service of process of new 0.40 178.00 lawsuits on the Greater Niagara Frontier Council not previously reviewed and add same to the New York litigation tracking spreadsheet. 08/27/20 SEM PHASE1 Review service of process documents 0.30 133.50 and lawsuit filed in New York for Timothy Singhel against the Suffolk County, Katahdin and Baden Powell Councils and notify defense counsel of service of same. 08/27/20 SEM PHASE1 Email to Suffolk County, Katahdin 0.50 222.50 Area and Baden Powell Councils regarding service of process in the Timothy Singhel case and handling of the same. 08/27/20 SEM PHASE1 Multiple emails exchanged and a 0.50 222.50 telephone call with BSA regarding new lawsuit filed in Missouri and to stand down on the same as it s being Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 61 of 74
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Date Initials Stage Description Hours Amount handled as an employment matter. 08/27/20 SEM PHASE1 Email exchange with Missouri 0.20 89.00 defense counsel regarding new lawsuit and need to stand down as BSA employment counsel is handling. 08/27/20 SEM PHASE1 Conference call with Kentucky 0.40 178.00 defense counsel regarding insurance adjuster's potential conflict of interest, bankruptcy case update, and expectation for settlement of the LFL matters. 08/27/20 SEM PHASE1 Email exchange with Sidley and 0.30 133.50 Kentucky defense counsel regarding the effect on their continued defense of BSA and LFL if they file a proof of claim for their lost fees. 08/27/20 SEM PHASE1 Email from Baden-Powell Council in 0.10 44.50 New York with notice of service of process of four (4) more lawsuits. 08/27/20 SEM PHASE1 Review service of process documents 0.30 133.50 received from Baden-Powell Council, process same and forward to New York defense counsel. 08/27/20 SEM PHASE1 Review information and documents 0.40 178.00 received from the Longhouse Council in New York regarding new lawsuits, add information to the litigation tracking spreadsheet and forward same to BSA. 08/27/20 SEM PHASE1 Begin to review BSA internal files for 1.50 667.50 recently identified New York alleged perpetrators in new lawsuits. 08/27/20 SEM PHASE1 Email exchange with Greater Niagara 0.30 133.50 Frontier and Seneca Waterways Councils in New York regarding information related to newly served Thomas McDonald case. 08/27/20 SEM PHASE1 Review information received from the 0.20 89.00 Seneca Waterways Council in regard to the Thomas McDonald lawsuit and update the New York litigation Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 62 of 74
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Date Initials Stage Description Hours Amount tracking spreadsheet with the same. 08/27/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding complaint filed by Michael Lolya. 08/27/20 KAD PHASE1 Review email and documentation 0.20 38.00 received from Greater New York Councils regarding various newly filed New York cases. 08/27/20 KAD PHASE1 Email exchange with Anna Kutz 0.10 19.00 regarding completion of service of process on Katahdin Area Council and updating Timothy Singhel claim record in Riskonnect with same. 08/27/20 KAD PHASE1 Update Timothy Singhel claim record 0.10 19.00 in Riskonnect to reflect completion of service of process on Katahdin Area Council. 08/27/20 KAD PHASE1 Email exchange with Anna Kutz 0.10 19.00 regarding completion of service of process on Rip Van Winkle Council and updating Louis Morales claim record in Riskonnect with same. 08/27/20 KAD PHASE1 Update Louis Morales claim record in 0.10 19.00 Riskonnect to reflect completion of service of process on Rip Van Winkle Council. 08/27/20 KAD PHASE1 Email exchange with Anna Kutz 0.10 19.00 regarding completion of service of process on Westchester-Putnam Council and updating Michael Lolya claim record in Riskonnect with same. 08/27/20 KAD PHASE1 Update Michael Lolya claim record in 0.10 19.00 Riskonnect to reflect completion of service of process on Westchester- Putnam Council. 08/27/20 KAD PHASE1 Review email from Lynn Sammon 0.10 19.00 regarding completion of service of process on Greater New York Councils in connection with the JMBXI Doe lawsuit. 08/27/20 KAD PHASE1 Email exchange with Nicole 0.10 19.00 Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 63 of 74
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Date Initials Stage Description Hours Amount Liberatore regarding notices of second stipulation and agreed order filed in 2 new, New York lawsuits. 08/28/20 BAG PHASE1 Review complaint in Philius v BSA 0.50 320.00 and internal communications with Sean Manning regarding same. 08/28/20 SEM PHASE1 Continue reviewing BSA internal files 7.60 3,382.00 located for alleged perpetrators identified in recent New York lawsuits and update the litigation tracking spreadsheet as necessary. 08/28/20 SEM PHASE1 Receive and review and respond to 0.50 222.50 nine (9) emails from the Longhouse Council in response to recently received lawsuits. 08/28/20 SEM PHASE1 Email exchange with Longhouse 0.20 89.00 Council regarding service of Process in the Timothy Tuttle and Terrill Root, Jr cases. 08/28/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 recent New York complaints that name Stanley Bratt and provide information in regard to the same. 08/28/20 SEM PHASE1 Multiple email exchanges with 0.30 133.50 Greater New York Councils regarding service of process on the council today in the Fiske, Philius and Mandracchia cases. 08/28/20 SEM PHASE1 Review Weekly New Claims Report 0.10 44.50 create by Kelci Davis to ensure all new claims have been processed. 08/28/20 SEM PHASE1 Email exchange with Kentucky 0.20 89.00 defense counsel regarding court order staying entire action in the S.R.X. case and review said order. 08/28/20 SEM PHASE1 Email exchange with Katahdin Area 0.20 89.00 Council regarding service of process in the Singhel case. 08/28/20 SEM PHASE1 Email from Greater New York 0.10 44.50 Councils with information and documents related to more new Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 64 of 74
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Date Initials Stage Description Hours Amount recently filed lawsuits. 08/28/20 SEM PHASE1 Multiple email exchanges with the 0.30 133.50 Suffolk County Council regarding service of process in the Singhel, Redden, and Krimmenecker lawsuits. 08/28/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding JMBX1 Complaint. 08/28/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding lawsuit filed by Michael McLoughlin and request for information to the Council regarding same. 08/28/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding Anonymous Erie and AB 408 Doe lawsuits. 08/28/20 KAD PHASE1 Review rosters received from 0.20 38.00 Longhouse Council in connection with recently filed New York lawsuits. 08/28/20 KAD PHASE1 Analyze lawsuit filed by AB 422 Doe 0.20 38.00 in preparation of entering same in Riskonnect. 08/28/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by AB 422 Doe. 08/28/20 KAD PHASE1 Analyze lawsuit filed by AB 423 Doe 0.20 38.00 in preparation of entering same in Riskonnect. 08/28/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by AB 423 Doe. 08/28/20 KAD PHASE1 Review email from Lynn Sammon 0.10 19.00 regarding completion of service of process on Greater New York Councils in connection with the Timothy Fiske lawsuit. 08/28/20 KAD PHASE1 Email Anna Kutz regarding 0.10 19.00 completion of service of process on Greater New York Councils and updating Timothy Fiske claim record with same. 08/28/20 KAD PHASE1 Update Timothy Fiske claim record in 0.10 19.00 Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 65 of 74
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Date Initials Stage Description Hours Amount Riskonnect to reflect completion of service of process on Greater New York Councils. 08/28/20 KAD PHASE1 Email Anna Kutz regarding 0.10 19.00 completion of service of process on Greater New York Councils and updating Charles Mandracchia claim record with same. 08/28/20 KAD PHASE1 Review email from Lynn Sammon 0.10 19.00 regarding completion of service of process on Greater New York Councils in connection with the Charles Mandracchia lawsuit. 08/28/20 KAD PHASE1 Update Charles Mandracchia claim 0.10 19.00 record in Riskonnect to reflect completion of service of process on Greater New York Councils. 08/28/20 KAD PHASE1 Email Anna Kutz regarding 0.10 19.00 completion of service of process on Greater New York Councils and updating Reynolds Philius claim record with same. 08/28/20 KAD PHASE1 Review email from Lynn Sammon 0.10 19.00 regarding completion of service of process on Greater New York Councils in connection with the Reynolds Philius lawsuit. 08/28/20 KAD PHASE1 Update Reynold Philius claim record 0.10 19.00 in Riskonnect to reflect completion of service of process on Greater New York Councils. 08/28/20 KAD PHASE1 Prepare weekly new claims report. 1.90 361.00 08/28/20 KAD PHASE1 Email Sidley Austin, Alvarez Marsal, 0.10 19.00 BSA and Monica Blacker regarding weekly new abuse claims report. 08/28/20 KAD PHASE1 Analyze lawsuit filed by AB 424 Doe 0.20 38.00 in preparation of entering same in Riskonnect. 08/28/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by AB 424 Doe. Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 66 of 74
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Date Initials Stage Description Hours Amount 08/31/20 BAG PHASE1 Exchange email with Paul Needham 0.20 128.00 at Aspen Insurance regarding status of multiple claims. 08/31/20 BAG PHASE1 Review and respond to Allie Meyer at 0.10 64.00 Everest Insurance regarding claim status. 08/31/20 BAG PHASE1 Review Order on Plaintiff's Motion to 0.10 64.00 Compel in John Doe (NM) v BSA. 08/31/20 BAG PHASE1 Review email from Paul Needham at 0.20 128.00 Aspen Insurance regarding C.J. (OH) v BSA matter and attention to same. 08/31/20 BAG PHASE1 Review complaint in the Wagner v 0.30 192.00 Fort Stanwix Council matter and internal communications with Sean Manning regarding same. 08/31/20 BAG PHASE1 Review complaint in the Withrow v 0.30 192.00 Land of the Oneidas Council matter and internal communications with Sean Manning regarding same. 08/31/20 SEM PHASE1 Review news article regarding former 0.20 89.00 Greater Niagara Frontier Council board president arrested for child molestation and email same to BSA. 08/31/20 SEM PHASE1 Review email string with Kansas City 0.30 133.50 BSA employment defense counsel and BSA and briefly discuss same with defense counsel. 08/31/20 SEM PHASE1 Review Jane Doe v. Heart of America 0.50 222.50 Council Complaint prior to conference call with Kansas City employment defense counsel. 08/31/20 SEM PHASE1 Email to Kansas City employment 0.30 133.50 defense counsel with links and documents related to BSA youth protection policies and camp staff guidelines. 08/31/20 SEM PHASE1 Conference call with Kansas City 0.50 222.50 employment defense counsel regarding details of the case and BSA structure and materials related to the new Jane Doe case against the Heart Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 67 of 74
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Date Initials Stage Description Hours Amount of America Council. 08/31/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 the Edward Redden lawsuit in New York. 08/31/20 SEM PHASE1 Review documents and information 1.50 667.50 received from the Longhouse Council related to newly filed lawsuits, update litigation tracking spreadsheet and and forward same to BSA. 08/31/20 SEM PHASE1 Gather information and email New 0.20 89.00 York defense counsel to advise of service of process on the Longhouse Council in the Tuttle and Root matters. 08/31/20 SEM PHASE1 Gather information and email New 0.20 89.00 York defense counsel to advise of service of process on the Greater New York Councils in the Fiske, Philius and Mandracchia matters. 08/31/20 SEM PHASE1 Gather information from the Katahdin 0.20 89.00 and Suffolk County Councils regarding service of process in the Timothy Singhel case and send same to New York defense counsel. 08/31/20 SEM PHASE1 Gather information from the Suffolk 0.20 89.00 County Council regarding service of process in the Redden and Krummenecker cases and send same to New York defense counsel. 08/31/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 Anonymous (Erie) and AB 408 Doe cases in New York. 08/31/20 SEM PHASE1 Email exchange with Sidley regarding 0.30 133.50 updates to the Consent Order Schedules and clarification regarding alleged chartered organizations. 08/31/20 SEM PHASE1 Email exchange with Baden-Powell 0.30 133.50 Council and BSA regarding correspondence received from the insurance carrier for the Roman Catholic Diocese of Syracuse relating Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 68 of 74
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Date Initials Stage Description Hours Amount to the John Doe 17 case. 08/31/20 SEM PHASE1 Research John Doe 17 case in New 0.20 89.00 York to confirm position on co- defrendants as potential BSA related entities. 08/31/20 SEM PHASE1 Email to New York defense counsel 0.20 89.00 to discuss issues surrounding John Doe 17 R.H. case and seek additional details from Plaintiff's counsel. 08/31/20 SEM PHASE1 Email exchange with Suffolk County 0.30 133.50 Council in New York regarding information related to Squelch and Schaefer case, update litigation tracking spreadsheet and forward same to BSA. 08/31/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 follow-up with councils where D.C. plaintiffs come from in regard to additional information and documents. 08/31/20 SEM PHASE1 Review Craig Bleau and R.E.M. 0.80 356.00 lawsuit against the Longhouse Council and compare same to the C.B. case to determine if the plaintiff's are one in the same and send information related to the same to BSA. 08/31/20 SEM PHASE1 Email exchange with the Longhouse 0.30 133.50 Council regarding R.E.M. case and review rosters located in relation to the same. 08/31/20 SEM PHASE1 Email from New Mexico defense 0.20 89.00 counsel with Order on Plaintiff’s First Motion to Compel Discovery of Defendant Richard Lucero for Plaintiff’s First Discovery Requests and review the same. 08/31/20 SEM PHASE1 Review email exchange between 0.10 44.50 Everest Insurance and BSA confirming all pending matters continue to be stayed. Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 69 of 74
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Date Initials Stage Description Hours Amount 08/31/20 SEM PHASE1 Email exchange with Kansas City 0.30 133.50 employment defense counsel regarding prior and pending claims against the Heart of America Council that may have documents or information related to the current matter and review the same. 08/31/20 SEM PHASE1 Review information and documents 0.40 178.00 received from the Greater New York Councils in relation to newly filed lawsuits, update the litigation tracking spreadsheet and forward same to the BSA. 08/31/20 SEM PHASE1 Request BSA internal files for alleged 0.10 44.50 perpetrators in New York cases filed only against alleged chartered organizations in order to try to locate additionally useful information. 08/31/20 SEM PHASE1 Email to the Twin Rivers Council 0.10 44.50 regarding follow-up on request to confirm alleged chartered organizations. 08/31/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 the Timothy Tuttle case in New York and request for complaint. 08/31/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 notices of service of process on the Leatherstocking Council in the Wagner and Withrow cases. 08/31/20 SEM PHASE1 Email exchange with BSA related to 0.20 89.00 records received from the Longhouse council for the Chris Jeffries case. 08/31/20 SEM PHASE1 Email from BSA regarding information 0.20 89.00 requested for Jefferies cases in Longhouse Council and forward same to council seeking the same. 08/31/20 KAD PHASE1 Email exchange with Anna Kutz 0.10 19.00 regarding record of an abuse claim for J.B. 08/31/20 KAD PHASE1 Review email and documents from 0.20 38.00 Greater New York Council regarding Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 70 of 74
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Date Initials Stage Description Hours Amount newly filed New York lawsuits. 08/31/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding Complaint filed by John Doe 8 (DC) and request for information to the Council regarding same. 08/31/20 KAD PHASE1 Review email from Vanessa Savoy 0.10 19.00 regarding month-end reporting and changes to Riskonnect, forward same to Katie Murray. 08/31/20 KAD PHASE1 Email exchange with Anna Kutz 0.10 19.00 regarding entering John Doe 17 R.H. claim into Riskonnect. 08/31/20 KAD PHASE1 Email William Curtain and Andres 0.10 19.00 Barajas regarding Schedule 1 and due date for same. 08/31/20 KAD PHASE1 Analyze lawsuit filed by AB 425 Doe 0.20 38.00 in preparation of entering same in Riskonnect. 08/31/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by AB 425 Doe. 08/31/20 KAD PHASE1 Calculate the number of claims 0.30 57.00 pending against the Heart of America Council. 08/31/20 KAD PHASE1 Begin research and gather BSA 1.40 266.00 expert witness dossier material to provide to BSA local councils should they be removed from the bankruptcy process. 08/31/20 KAD PHASE1 Email exchange with Kathleen 0.10 19.00 Russell regarding the Court's Order on Plaintiff's First Motion to Compel Discovery of Defendant Richard Lucero. 08/31/20 KAD PHASE1 Review the Court's Order on 0.10 19.00 Plaintiff's First Motion to Compel Discovery of Defendant Richard Lucero. 08/31/20 KAD PHASE1 Review multiple emails and 0.20 38.00 documents from Longhouse Council Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 71 of 74
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Date Initials Stage Description Hours Amount regarding investigation of various newly filed New York lawsuits. 08/31/20 KAD PHASE1 Update Timothy Tuttle claim record in 0.10 19.00 Riskonnect to reflect completion of service upon Longhouse Council. 08/31/20 KAD PHASE1 Update Terrill Root claim record in 0.10 19.00 Riskonnect to reflect completion of service upon Longhouse Council. 08/31/20 KAD PHASE1 Begin revising Schedule 1 Chart of 3.00 570.00 Pending Abuse Actions.
Total Services: 295.20 115,452.50
Timekeeper Summary Timekeeper Title Rate Hours Amount Bruce A. Griggs Shareholder 640.00 51.60 33,024.00 Sean E. Manning Of Counsel 445.00 141.90 63,145.50 Kelci A. Davis Paralegal 190.00 100.70 19,133.00 Katie J. Murray Other 150.00 1.00 150.00 Expenses Description Amount VENDOR: Epiq eDiscovery Solutions, Inc.- AZ INVOICE#: 90464512 DATE: 8/8/2020 81.19 Professional Fees - Epiq eDiscovery Solutions, Inc.- AZ - E-discovery hosting fees - on 07/01/20 Total Expenses 81.19
TOTAL FEES $115,452.50 TOTAL EXPENSES $81.19 TOTAL THIS BILL $115,533.69 Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 72 of 74
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 September 15, 2020 Telephone: (864) 241-1801 Facsimile: (864) 241-1908
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 # 90277231 Client.Matter # 083331.000000
Re: Boy Scouts of America, The - General Advice
For professional services rendered through August 31, 2020, in connection with the above-referenced matter as outlined on the attached detailed billing sheets:
Fees ...... $3,400.20 Expenses...... $19.12
Total Due This Bill...... $3,419.32
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 1392-2 Filed 10/01/20 Page 73 of 74
Page 2 09/15/20 Bill No. 90277231 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 August 31, 2020
Date Initials Stage Description Hours Amount 08/10/20 GSM PHASE1 Begin drafting monthly status report 0.30 124.20 update for all pending matters. 08/14/20 GSM PHASE1 Analyze several emails, text 1.00 414.00 messages, and severance agreement pertaining to former employee, and discuss same with Lisa Young. 08/17/20 GSM PHASE1 Draft cease and desist letter to former 2.30 952.20 employee in North Carolina while analyzing various documents and emails regarding same, and correspond with Lisa Young regarding same. 08/18/20 GSM PHASE1 Begin analyzing summary of 0.30 124.20 investigation regarding shooting range in Wisconsin and email from Cynthia Speer regarding same. 08/19/20 GSM PHASE1 Analyze and make substantive 2.20 910.80 revisions to detailed investigative findings and recommendations regarding shooting range in Wisconsin. 08/20/20 GSM PHASE1 Revise cease and desist letter to 0.60 248.40 North Carolina employee, and correspond with Lisa Young regarding same. 08/20/20 GSM PHASE1 Exchange emails with Cynthia Speer 0.10 41.40 regarding investigative summary of incident at shooting range in Wisconsin. 08/28/20 GSM PHASE1 Draft detailed analysis for Bill Davis 1.10 455.40 regarding implications of extending Case 20-10343-LSS Doc 1392-2 Filed 10/01/20 Page 74 of 74
Page 3 09/15/20 Bill No. 90277231 083331.000000-RWC
Date Initials Stage Description Hours Amount certain furloughs, and discuss same with Mr. Davis on the phone. 08/29/20 RWC PHASE1 Emails from and to Elizabeth Washka 0.20 129.60 regarding employee issue, gather information responsive to Ms. Washka’s questions, and provide answers to same.
Total Services: 8.10 3,400.20
Timekeeper Summary Timekeeper Title Rate Hours Amount Gavin S. Martinson Shareholder 414.00 7.90 3,270.60 Ron Chapman, Jr. Shareholder 648.00 0.20 129.60 Expenses Description Amount Express Delivery/Postage 1.00 @ 19.12 ea. 19.12 Total Expenses 19.12
TOTAL FEES $3,400.20 TOTAL EXPENSES $19.12 TOTAL THIS BILL $3,419.32 Case 20-10343-LSS Doc 1392-3 Filed 10/01/20 Page 1 of 6 Case 20-10343-LSS Doc 1392-3 Filed 10/01/20 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 September 15, 2020 Telephone: (864) 241-1801 Facsimile: (864) 241-1908
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 # 90275793 Client.Matter # 047657.000013
Re: BSA General Defense - Bankruptcy (Billiable)
For professional services rendered through August 31, 2020, in connection with the above-referenced matter as outlined on the attached detailed billing sheets:
Fees ...... $11,108.00 Expenses...... $0.00
Total Due This Bill...... $11,108.00
Atlanta ▪ Austin ▪ Berlin (Germany) ▪ Birmingham ▪ Boston ▪ Charleston ▪ Charlotte ▪ Chicago ▪ Cleveland ▪ Columbia ▪ Dallas ▪ Denver ▪ Detroit Metro ▪ Greenville ▪ Houston Indianapolis ▪ Jackson ▪ Kansas City ▪ Las Vegas ▪ London (England) ▪ Los Angeles ▪ Memphis ▪ Mexico City (Mexico) ▪ Miami ▪ Milwaukee ▪ Minneapolis ▪ Montréal (Canada) ▪ Morristown Nashville ▪ New Orleans ▪ New York City ▪ Oklahoma City ▪ Orange County ▪ Paris (France) ▪ Philadelphia ▪ Phoenix ▪ Pittsburgh ▪ Portland, ME ▪ Portland, OR ▪ Raleigh Richmond ▪ St. Louis ▪ St. Thomas ▪ Sacramento ▪ San Antonio ▪ San Diego ▪ San Francisco ▪ Seattle ▪ Stamford ▪ Tampa ▪ Toronto (Canada) ▪ Torrance ▪ Tucson ▪ Washington Case 20-10343-LSS Doc 1392-3 Filed 10/01/20 Page 3 of 6
Page 2 09/15/20 Bill No. 90275793 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 August 31, 2020
Date Initials Stage Description Hours Amount 08/04/20 KAD PHASE2 Email exchange with Anna Kutz 0.10 19.00 regarding Wilson and Elser's OCP declaration. 08/06/20 BAG PHASE2 Review email and certificate of non- 0.20 128.00 objection received from Laura Nichols and attention to same. 08/06/20 KAD PHASE2 Email exchange with Yesmy Romero 0.10 19.00 regarding billing process and information for New York lawsuits newly assigned to Wiggin and Dana. 08/06/20 KAD PHASE2 Analyze and revise July's billing 3.90 741.00 entries and information for inclusion in the monthly fee application for August. 08/06/20 KAD PHASE2 Compile billing information on 30 1.80 342.00 newly filed New York lawsuits assigned to Wiggin and Dana per Yesmy Romero's request. 08/10/20 BAG PHASE2 Begin review and redaction of 2.00 1,280.00 monthly invoices in preparation for submission of monthly fee. 08/11/20 KAD PHASE2 Analyze Epic invoice and submit 0.10 19.00 same for processing. 08/12/20 BAG PHASE2 Complete review and redaction of 0.50 320.00 privileged information for monthly fee application. 08/13/20 KAD PHASE2 Begin final review of July's draft 0.90 171.00 billing entries for inclusion in the monthly fee application for August. Case 20-10343-LSS Doc 1392-3 Filed 10/01/20 Page 4 of 6
Page 3 09/15/20 Bill No. 90275793 047657.000013-BAG
Date Initials Stage Description Hours Amount 08/14/20 KAD PHASE2 Finish final review of July's draft 2.10 399.00 billing entries for inclusion in the monthly fee application for August. 08/17/20 BAG PHASE2 Review monthly charts and work on 0.50 320.00 monthly fee application. 08/17/20 KAD PHASE2 Email exchange with Desiree Vale 0.10 19.00 regarding Ogletree's monthly fee applications. 08/17/20 KAD PHASE2 Prepare initial draft of Ogletree's Fifth 3.20 608.00 Monthly Fee Application. 08/17/20 KAD PHASE2 Review/analyze billing entries and 3.80 722.00 invoices for inclusion in Ogletree's Fifth Monthly Fee Application and work on required redaction for same. 08/18/20 BAG PHASE2 Complete work on monthly fee 0.50 320.00 application. 08/18/20 KAD PHASE2 Revise Ogletree's 5th Monthly Fee 0.20 38.00 Application. 08/18/20 KAD PHASE2 Finish reviewing/analyzing billing 3.60 684.00 entries and invoices for inclusion in Ogletree's Fifth Monthly Fee Application and work on required redaction for same. 08/19/20 SEM PHASE2 Email exchange with Hawaii defense 0.20 89.00 counsel regarding billing and payment issues related to the John Roe 120 case. 08/19/20 SEM PHASE2 Email to BSA regarding billing and 0.20 89.00 payment issues Hawaii defense counsel is having with Chubb Insurance. 08/19/20 SEM PHASE2 Review issue of non-payment of fees 0.10 44.50 to Hawaii defense counsel by CHUBB with Bruce Griggs. 08/19/20 KAD PHASE2 Finalize Ogletree's 5th Monthly Fee 0.40 76.00 Application. 08/19/20 KAD PHASE2 Email Paige Topper regarding 0.10 19.00 Ogletree's Fifth Monthly Fee Application. Case 20-10343-LSS Doc 1392-3 Filed 10/01/20 Page 5 of 6
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Date Initials Stage Description Hours Amount 08/19/20 KAD PHASE2 Review email from Adrian Lavarias 0.10 19.00 regarding coverage dispute and submitting invoices to the carrier for payment. 08/20/20 SEM PHASE2 Email discussion with Sidley 0.30 133.50 regarding payment of Kentucky defense counsel on old unpaid invoice that did not get properly submitted prior to the bankruptcy filing. 08/24/20 SEM PHASE2 Email exchange with New York 0.20 89.00 defense counsel regarding CHUBB billing information for several newly filed lawsuits against the Twin Rivers Council. 08/24/20 KAD PHASE2 Email exchange with Eric Moats 0.10 19.00 regarding unredacted invoices. 08/24/20 KAD PHASE2 Compile billing information and 1.10 209.00 instructions on newly filed New York cases assigned to Lewis Brisbois. 08/24/20 KAD PHASE2 Email exchange with John Anselmo 0.10 19.00 regarding billing information and instructions for various newly filed New York lawsuits assigned to Lewis Brisbois. 08/25/20 SEM PHASE2 Email exchange with Missouri 0.20 89.00 defense counsel regarding billing for the John Doe workers compensation matter. 08/26/20 BAG PHASE2 Work on second interim fee 1.50 960.00 application and all related information. 08/26/20 SEM PHASE2 Email exchange with New York 0.20 89.00 defense counsel regarding billing information for newly assigned lawsuits. 08/26/20 KAD PHASE2 Email exchange with Eric Moats 0.10 19.00 regarding the Second Interim Fee Application. 08/26/20 KAD PHASE2 Email exchange with Desiree Vale 0.10 19.00 regarding the CNO for Ogletree's Case 20-10343-LSS Doc 1392-3 Filed 10/01/20 Page 6 of 6
Page 5 09/15/20 Bill No. 90275793 047657.000013-BAG
Date Initials Stage Description Hours Amount Fourth Monthly Fee Application. 08/26/20 KAD PHASE2 Begin working on Ogletree's Second 5.40 1,026.00 Interim Fee Application. 08/27/20 KAD PHASE2 Email Karen Campbell regarding 0.10 19.00 process for handling invoices pertaining to the James Temple claim. 08/27/20 KAD PHASE2 Email exchange with Desiree Vale 0.10 19.00 regarding Ogletree's Fifth Monthly Fee Application. 08/27/20 KAD PHASE2 Continue work on second interim fee 6.30 1,197.00 application, including compilation and analysis of all requested data and information. 08/28/20 BAG PHASE2 Complete work on second interim fee 1.00 640.00 application. 08/28/20 KAD PHASE2 Revise Second Interim Fee 0.30 57.00 Application based on information received from Brian Whittman. 08/31/20 KAD PHASE2 Conference call with Kayron at Lewis 0.10 19.00 Brisbois regarding billing on Hartford claims.
Total Services: 41.90 11,108.00
Timekeeper Summary Timekeeper Title Rate Hours Amount Bruce A. Griggs Shareholder 640.00 6.20 3,968.00 Sean E. Manning Of Counsel 445.00 1.40 623.00 Kelci A. Davis Paralegal 190.00 34.30 6,517.00
TOTAL FEES $11,108.00 TOTAL EXPENSES $0.00 TOTAL THIS BILL $11,108.00 Case 20-10343-LSS Doc 1392-4 Filed 10/01/20 Page 1 of 1