Case 20-10343-LSS Doc 1625 Filed 11/03/20 Page 1 of 11
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. Objection Deadline: Nov. 17, 2020 at 4:00 p.m. (ET)
SUMMARY COVER SHEET OF SEVENTH MONTHLY APPLICATION OF OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C. FOR ALLOWANCE OF COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR THE PERIOD FROM SEPTEMBER 1, 2020 TO AND INCLUDING SEPTEMBER 30, 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: September 1, 2020 – September 30, 2020
Amount of Compensation Requested: $87,638.96 (80% of $109,548.70)2
Amount of Compensation Requested from $63,081.60 Insurers:
Amount of Expense Reimbursement Requested: $81.19
Amount of Expense Reimbursement Requested $0.00 from Insurers:
This is a(n): monthly x interim final application
1 The Debtors in these chapter 11 cases, together with the last four digits of each Debtor’s federal tax identification number, are as follows: Boy Scouts of America (6300) and Delaware BSA, LLC (4311). The Debtors’ mailing address is 1325 West Walnut Hill Lane, Irving, Texas 75038. 2 The amount of compensation and fees requested does not include fees and expenses to be paid directly to Ogletree Deakins by one or more insurance carriers in certain non-abuse claims or cases. While Ogletree Deakins reserves the right to seek future payment from the Debtors for such claims and cases, at this time Ogletree Deakins is not seeking payment from the Debtors on these claims and cases.
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PRIOR MONTHLY APPLICATIONS FILED
Requested Approved Outstanding Date Period Filed; Fees Expenses Fees Expenses Fees Expenses Covered Docket No. February 4/29/2020; 18, 2020 – Docket No. $393,030.80 $1,923.42 $393,030.80 $1,923.42 $0 $0 March 31, 512 2020 April 1, 5/28/2020; 2020 – Docket No. $146,042.10 $128.96 $146,042.10 $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 $0 $0 May 31, 867 2020 June 1, 7/22/2020; 2020 – Docket No. $133,225.40 $81.19 $106,580.32 $81.19 $0 $0 June 30, 1037 2020 8/21/2020; July 1, Docket No. 2020 – July $136,960.85 $81.19 $109,544.68 $81.19 $0 $0 1137 31, 2020 August 1, 10/1/2020; 2020 – Docket No. $129,960.70 $100.31 $103,968.56 $100.31 $83,174.85 $100.31 August 31, 1392 2020 September 1, 2020 – TBD $109,548.70 $81.19 TBD TBD $87,638.96 $81.91 September 30, 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 23.1 $14,784.00 Gavin Martinson Shareholder 2005 / 15 $440.00 16.2 $6,706.80 Ronald W. Chapman Shareholder 1995 / 25 $650.00 0.2 $129.60 Jennifer Colvin Shareholder 2001 / 19 $530.00 0.6 $297.00 Nonnie Shivers Shareholder 2004 / 16 $515.00 0.2 $92.70 Michael Shetterly Shareholder 1996 / 24 $480.00 0.2 $89.10
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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Year of Position Admission Hourly Total Total Name Area of / Years of Rate Hours3 Compensation Expertise Experience Sean E. Manning Of Counsel 2001 / 19 $425.00 135.5 $60,297.50 Kelci A. Davis Paralegal N/A $190.00 141.8 $26,942.00 Katie Murray Other N/A $150.00 1.4 $210.00 Total 319.2 $109,548.70
iii Case 20-10343-LSS Doc 1625 Filed 11/03/20 Page 4 of 11
COMPENSATION AND EXPENSES BY PROJECT CATEGORY
Task Description Total Hours Total Compensation
Litigation/Claims / Phase 1 292.4 $102,427.20 Retention Issues / Phase 2 26.8 $7,121.50 Plan Issues / Phase 3 0 $0 Non-working Travel / Phase 4 0 $0 TOTAL 319.2 $109,548.70
iv Case 20-10343-LSS Doc 1625 Filed 11/03/20 Page 5 of 11
EXPENSES BY CATEGORY
Category Amount Legal Support Services $81.19 TOTAL: $81.19
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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE
In re: Chapter 11
BOY SCOUTS OF AMERICA AND Case No. 20-10343 (LSS) DELAWARE BSA, LLC,1 (Jointly Administered)
Debtors. Objection Deadline: Nov. 17, 2020 at 4:00 p.m. (ET)
SEVENTH MONTHLY APPLICATION OF OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C. FOR ALLOWANCE OF COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR THE PERIOD FROM SEPTEMBER 1, 2020 TO SEPTEMBER 30, 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 seventh monthly application (this “Application”) requesting payment in
the aggregate amount of $87,638.96, which is equal to (a) 80% of the $109,548.70 of total
compensation earned by Ogletree Deakins for its services to the Debtors during the period from
September 1, 2020 to and including September 30, 2020 (the “Fee Period”) and (b) 100% of the
$81.19 of necessary expenses incurred by Ogletree Deakins during the Fee Period in connection
with its services to the Debtors.2 In support of this Application, Ogletree Deakins respectfully
represents as follows:
1The Debtors in these chapter 11 cases, together with the last four digits of each Debtor’s federal tax identification number, are as follows: Boy Scouts of America (6300) and Delaware BSA, LLC (4311). The Debtors’ mailing address is 1325 West Walnut Hill Lane, Irving, Texas 75038. 2 The amount of compensation and fees requested does not include fees and expenses to be paid directly to Ogletree Deakins by one or more insurance carriers in certain non-abuse claims or cases. While Ogletree Deakins reserves the right to seek future payment from the Debtors for such claims and cases, at this time Ogletree Deakins is not seeking payment from the Debtors on these claims and cases.
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JURISDICTION AND VENUE
1. The United States Bankruptcy Court for the District of Delaware (the “Court”) has
jurisdiction over this matter pursuant to 28 U.S.C. § 1334 and the Amended Standing Order of
Reference from the United States District Court for the District of Delaware, dated February 29,
2012. This matter is a core proceeding within the meaning of 28 U.S.C. § 157(b)(2). Venue is
proper in this district pursuant to 28 U.S.C. §§ 1408 and 1409.
2. The statutory and other bases for the relief requested herein are sections 330 and
331 of chapter 11 of title 11 of the United States Code, 11 U.S.C. §§ 101–1532 (the “Bankruptcy
Code”), rule 2016 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), rule
2016-2 of the Local Rules of Bankruptcy Practice and Procedure of the United States Bankruptcy
Court for the District of Delaware (the “Local Rules”), and the Order (I) Approving Procedures
for (A) Interim Compensation and Reimbursement of Expenses of Retained Professionals and
(B) Expense Reimbursement for Official Committee Members and (II) Granting Related Relief
[Docket No. 341] (the “Compensation Procedures Order”).
BACKGROUND
3. On February 18, 2020 (the “Petition Date”), each of the Debtors filed a voluntary
petition with the Court for relief under chapter 11 of the Bankruptcy Code. The Debtors continue
to operate and maintain their non-profit organization and manage their properties as debtors in
possession pursuant to sections 1107(a) and 1108 of the Bankruptcy Code. On February 19, 2020,
the Court entered an order [Docket No. 61] authorizing the joint administration and procedural
consolidation of the chapter 11 cases pursuant to Bankruptcy Rule 1015(b).
4. The Debtors retained Ogletree Deakins as their special litigation counsel, nunc pro
tunc to the Petition Date, pursuant to the Order Authorizing the Retention and Employment of
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Ogletree, Deakins, Nash, Smoak & Stewart, P.C. as Special Litigation Counsel for the Debtors and Debtors in Possession, Nunc Pro Tunc to the Petition Date [Docket No. 364] (the “Retention
Order”). The Retention Order authorizes the Debtors to compensate and reimburse Ogletree
Deakins in accordance with the terms and conditions set forth in the Debtors’ application to retain
Ogletree Deakins, subject to Ogletree Deakins’ application to the Court.
5. On April 6, 2020, the Court entered the Compensation Procedures Order. The
Compensation Procedures Order provides, among other things, that each professional shall be
entitled, on or as soon as practicable after the fifteenth (15th) day of each month following the
month for which compensation and/or expense reimbursement is sought, to file and serve an
application for interim allowance of compensation earned and reimbursement of expenses incurred
during the preceding month (each a “Monthly Fee Application”). Parties shall have fourteen (14)
days after service of a Monthly Fee Application to file an objection to the compensation or
expenses that are the subject thereof (the “Objection Deadline”). Upon the expiration of the
Objection Deadline, the applicant may file a certificate of no objection (a “CNO”) with the Court
with respect to the unopposed portion of the fees and/or expenses requested in the applicable
Monthly Fee Application. After the filing of a CNO, the Debtors are authorized and directed to
pay the applicant an amount equal to 80% of the fees and 100% of the expenses requested in the
applicable Monthly Fee Application not subject to an objection.
RELIEF REQUESTED
6. By this Application, in accordance with the Compensation Procedures Order,
Ogletree Deakins requests payment in the aggregate amount of $87,638.96, which is equal to
(a) 80% of the $109,548.70 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 $81.19 of necessary expenses incurred by Ogletree Deakins during the Fee Period in connection with its services to the Debtors.
SUMMARY OF SERVICES RENDERED
7. Attached hereto as Exhibit A is a detailed statement of the time expended and compensation earned by Ogletree Deakins during the Fee Period with respect to Phase 1 tasks
(Litigation/Claims). Attached hereto as Exhibit B is a detailed statement of the time expended and compensation earned by Ogletree Deakins during the Fee Period with respect to Phase 2 tasks
(Retention Issues). Ogletree Deakins’ professionals expended a total of 319.2 hours in connection with these chapter 11 cases during the Fee Period. All services for which Ogletree Deakins is requesting compensation were performed for or on behalf of the Debtors. The services rendered by Ogletree Deakins during the Fee Period are categorized as set forth in Exhibit A and in the summary cover sheets prefixed to this Application. The professionals who provided services to the Debtors during the Fee Period are also identified in Exhibit A and in the summary cover sheets.
ACTUAL AND NECESSARY EXPENSES
8. Ogletree Deakins also incurred certain necessary expenses during the Fee Period for which it is entitled to reimbursement under the terms of its retention. As set forth in greater detail in the detailed statements attached hereto as Exhibits A and B and the expense summary attached hereto as Exhibit C, Ogletree Deakins’ total expenses incurred during the Fee Period are
$81.19.
VALUATION OF SERVICES
9. The hourly rates reflected on Exhibit A are Ogletree Deakins’ customary hourly rates for work of this character. The reasonable value of the services rendered by Ogletree Deakins for the Fee Period as to the Debtors in these chapter 11 cases is $109,548.70.
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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 (a)
$87,638.96, which is equal to 80% of the $109,548.70 of total compensation earned by Ogletree
Deakins during the Fee Period for its services to the Debtors, and (b) 100% of the $81.19 of necessary expenses incurred by Ogletree Deakins during the Fee Period in connection with its services to the Debtors, for a total interim award of $87,720.15.
Dated: November 3, 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: November 17, 2020, at 4:00 p.m. (ET)
NOTICE OF SEVENTH MONTHLY APPLICATION OF OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C. FOR ALLOWANCE OF COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR THE PERIOD FROM SEPTEMBER 1, 2020 TO SEPTEMBER 30, 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 Seventh Monthly Application of Ogletree, Deakins, Nash, Smoak & Stewart, P.C. for Allowance of Compensation and Reimbursement of Expenses for the Period from September 1, 2020 to September 30, 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 November 17, 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. proposed counsel to the Debtors: White & Case LLP, 111 South Wacker Drive, Chicago, Illinois 60606, Attn: Matthew E. Linder;
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
1 The Debtors in these cases, along with the last four digits of each Debtor’s federal EIN, are as follows: Boy Scouts of America (6300) and Delaware BSA, LLC (4311). The Debtors’ mailing address is 1325 West Walnut Hill Lane, Irving, Texas 75038.
Case 20-10343-LSS Doc 1625-1 Filed 11/03/20 Page 2 of 3
Buchbinder and Hannah M. McCollum;
vi. counsel to the Creditors’ Committee, Kramer Levin Naftalis & Frankel LLP, 1177 Avenue of the Americas, New York, New York 10036, Attn: Rachael Ringer and Megan M. Wasson;
vii. counsel to the Tort Claimants’ Committee, Pachulski Stang Ziehl & Jones LLP, 10100 Santa Monica Boulevard, 13th Floor, Los Angeles, California 90067, Attn: James I. Stang;
viii. counsel to the Future Claimants’ Representative, Young Conaway Stargatt & Taylor, LLP, Rodney Square, 1000 North King Street, Wilmington, Delaware 19801, Attn: Robert S. Brady and Edwin J. Harron;
ix. counsel to the Ad Hoc Committee of Local Councils, Wachtell, Lipton, Rosen & Katz, 51 West 52nd Street, New York, New York 10019, Attn: Richard G. Mason and Joseph C. Celentino;
x. counsel to JPMorgan Chase Bank, National Association, Norton Rose Fulbright US LLP, 2200 Ross Avenue, Dallas, Texas 75201-7932, Attn: Louis R. Strubeck and Kristian W. Gluck; and
xi. counsel to the County Commission of Fayette County (West Virginia), Steptoe & Johnson PLLC, Chase Tower – 8th Floor, 707 Virginia Street East, Charleston, West Virginia 25301, Attn: John Stump.
xii. Rucki Fee Review, LLC: 1111 Windon Drive, Wilmington, DE 19803, Attn: Justin Rucki.
A HEARING ON THE APPLICATION, IF NECESSARY, WILL BE HELD AT THE CONVENIENCE OF THE COURT AND NOTICE OF ANY SUCH HEARING WILL BE GIVEN ONLY TO THE OBJECTING PARTY OR PARTIES.
IF YOU FAIL TO RESPOND IN ACCORDANCE WITH THIS NOTICE, THE COURT MAY GRANT THE RELIEF REQUESTED BY THE APPLICATION WITHOUT FURTHER NOTICE OR HEARING.
[Remainder of Page Intentionally Left Blank]
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Dated: November 3, 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 –
WHITE & CASE LLP Jessica C. K. Boelter (admitted pro hac vice) 1221 Avenue of the Americas New York, New York 10020 Telephone: (212) 819-8200 Email: [email protected]
– and –
WHITE & CASE LLP Michael C. Andolina (admitted pro hac vice) Matthew E. Linder (admitted pro hac vice) 111 South Wacker Drive Chicago, Illinois 60606 Telephone: (212) 881-5400 Email: [email protected] [email protected]
Counsel and Proposed Co-Counsel for the Debtors and Debtors in Possession
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Exhibit A
Phase 1 Fees and Expense Itemization
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FILE COPY ONLY – BILL OGLETREE, DEAKINS, NASH, SUBMITTED ELECTRONICALLY SMOAK & STEWART, P.C. DO NOT SUBMIT TO CLIENT Attorneys at Law UNLESS EXPRESSLY Administrative Office REQUESTED BY CLIENT 50 International Drive Patewood IV, Suite 200 Greenville, SC 29615 October 20, 2020 Telephone: (864) 241-1801 Facsimile: (864) 241-1908 www.ogletreedeakins.com
Robyn Jungers The Boy Scouts of America Legal Department 1325 West Walnut Hill Lane P.O. Box 152079 Irving, TX 75015-2049
PERSONAL AND CONFIDENTIAL Bill # 90301668 Client.Matter # 047657.000013
Re: BSA General Defense - Bankruptcy (Billiable)
For professional services rendered through September 30, 2020, in connection with the above-referenced matter as outlined on the attached detailed billing sheets:
Fees ...... $95,112.00 Expenses...... $81.19
Total Due This Bill...... $95,193.19
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 1625-2 Filed 11/03/20 Page 3 of 79
Page 2 10/20/20 Bill No. 90301668 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 September 30, 2020
Date Initials Stage Description Hours Amount 09/01/20 BAG PHASE1 Review Complaint in Colwell v. 0.50 320.00 Westark Area Council and internal communications with Sean Manning regarding same. 09/01/20 BAG PHASE1 Review Complaint and service 0.50 320.00 information in McPhillips v. Hudson River Council and attention to same. 09/01/20 BAG PHASE1 Review email exchanges and 0.20 128.00 information received in Schwert v. BSA and attention to same. 09/01/20 BAG PHASE1 Review email and counsel 0.20 128.00 assignments in Greater Niagara Council matters. 09/01/20 BAG PHASE1 Review email and Complaint in P.L. 0.30 192.00 v. Greater Niagara Council and internal communications with Sean Manning regarding same. 09/01/20 BAG PHASE1 Review Complaints and service 0.50 320.00 information in Wagner and Withrow matters in NY and internal communications with S. Manning regarding same. 09/01/20 BAG PHASE1 Review media coverage regarding 0.20 128.00 notice issues. 09/01/20 SEM PHASE1 Email from New York defense 0.10 44.50 counsel regarding discussion with Plaintiff's counsel regarding the proper party defendant in the John Doe 17 R.H. case. Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 4 of 79
Page 3 10/20/20 Bill No. 90301668 047657.000013-BAG
Date Initials Stage Description Hours Amount 09/01/20 SEM PHASE1 Review Associated Press news story 0.30 133.50 regarding hearing on BSA motion to prevent plaintiff attorney advertising in the bankruptcy court. 09/01/20 SEM PHASE1 Email exchange with New York 0.20 89.00 defense counsel regarding parties being represented. 09/01/20 SEM PHASE1 Review service of process documents 0.20 89.00 received from the Leatherstocking Counsel in New York for Scott Wagner and send same to defense counsel with directions to respond to the same. 09/01/20 SEM PHASE1 Review service of process documents 0.20 89.00 received from the Leatherstocking Counsel in New York for Curtis Withrow and send same to defense counsel with directions to respond to the same. 09/01/20 SEM PHASE1 Review P.L. case filed in New York 0.20 89.00 against the Greater Niagara Frontier Council and summarize same for the litigation tracking spreadsheet. 09/01/20 SEM PHASE1 Email from Longhouse Council with 0.20 89.00 information sought by BSA in regard to Lochland Jefferies and forward same to BSA. 09/01/20 SEM PHASE1 Review information received from 0.30 133.50 Longhouse Council in New York related to Robert McGregor, update the litigation tracking spreadsheet and forward same to BSA. 09/01/20 SEM PHASE1 Review information received from 0.30 133.50 Longhouse Council in New York related to the JA-041 Doe case, update the litigation tracking spreadsheet and forward same to BSA. 09/01/20 SEM PHASE1 Email from BSA regarding service 0.20 89.00 and documents received from the Five Rivers Council in New York related to the Peter M. Schwert case Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 5 of 79
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Date Initials Stage Description Hours Amount and review email string related to the same. 09/01/20 SEM PHASE1 Review documents received from the 0.20 89.00 Five Rivers Council in New York related to the Peter M. Schwert case and respond to the council regarding the same. 09/01/20 SEM PHASE1 Email exchange with Kansas City 0.20 89.00 employment defense counsel regarding handling of BSA abuse cases and dealing with minor plaintiffs. 09/01/20 SEM PHASE1 Review BSA internal files for alleged 0.80 356.00 perpetrators in cases filed only against alleged chartered organizations and not a BSA entity in order to locate information that might confirm chartered organization status. 09/01/20 SEM PHASE1 Email from East Carolina Council with 0.20 89.00 information and records related to AIS claims and review same. 09/01/20 SEM PHASE1 Email exchange with Hudson Valley 0.20 89.00 Council regarding service of process in the Richard McPhillips case and review same. 09/01/20 SEM PHASE1 Email to New York defense counsel 0.20 89.00 with notice of service in the Richard McPhillips case. 09/01/20 SEM PHASE1 Review newly filed Richard McPhillips 0.30 133.50 case in New York and summarize the same for the litigation tracking spreadsheet. 09/01/20 SEM PHASE1 Email exchange with BSA regarding 0.40 178.00 new Arkansas lawsuit for Clifton Colwell, review email string regarding media request regarding the same, and search the master claims index to confirm the perpetrator is not otherwise identified in any other claim or case. 09/01/20 SEM PHASE1 Review new Clifton Colwell lawsuit 0.40 178.00 Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 6 of 79
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Date Initials Stage Description Hours Amount filed in Arkansas against the Westark Area Council and summarize claim details for local counsel and investigation of claims. 09/01/20 SEM PHASE1 Review BSA internal file for Francis 0.30 133.50 McCourt, alleged perpetrator in the new Arkansas lawsuit filed for Clifton Colwell. 09/01/20 SEM PHASE1 Email to Westark Area Council with 0.20 89.00 details from Clifton Colwell lawsuit and request for information related to the same. 09/01/20 SEM PHASE1 Email to Arkansas defense counsel 0.30 133.50 with assignment of Clifton Colwell lawsuit, facts regarding the same and direction to file initial BSA pleadings. 09/01/20 SEM PHASE1 Telephone call with Westark Area 0.30 133.50 Council regarding new Clifton Colwell lawsuit and background on the facts of the same. 09/01/20 SEM PHASE1 Review Richard McPhillips lawsuit 0.40 178.00 filed in New York against the chartered organization only and compare to the case he filed against the Hudson Valley Council. 09/01/20 SEM PHASE1 Email to Greater Niagara Frontier 0.10 44.50 Council in New York with information and complaint for the P.L. case and request for information. 09/01/20 SEM PHASE1 Email to New York defense counsel 0.10 44.50 with newly filed lawsuits against the Greater Niagara Frontier Council. 09/01/20 SEM PHASE1 Review BSA Washington D.C. multi- 2.00 890.00 plaintiff abuse lawsuit for information related to each individual plaintiff's claims, locate home councils and prepare to send requests to affected local councils. 09/01/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding insurance denial letter received in connection with John Doe Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 7 of 79
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Date Initials Stage Description Hours Amount 17 R.H. claim. 09/01/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding lawsuit filed by Daniel Davis. 09/01/20 KAD PHASE1 Email exchange with Anna Kutz 0.10 19.00 regarding completion of service on Leatherstocking Council in connection with the lawsuit filed by Curtis Withrow. 09/01/20 KAD PHASE1 Update Curtis Withrow claim record in 0.10 19.00 Riskonnect to reflect completion of service of process on Leatherstocking Council. 09/01/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding Chris Jeffries lawsuit and request for information to the Council regarding same. 09/01/20 KAD PHASE1 Email exchange with Kayron Headley 0.10 19.00 regarding representation of the Council in the newly assigned New York cases. 09/01/20 KAD PHASE1 Email exchange with Anna Kutz 0.10 19.00 regarding entering Peter Schwert case into Riskonnect. 09/01/20 KAD PHASE1 Email exchange with Anna Kutz 0.10 19.00 regarding completion of service on Leatherstocking Council in connection with the lawsuit filed by Scott Wagner. 09/01/20 KAD PHASE1 Update Scott Wagner claim record in 0.10 19.00 Riskonnect to reflect completion of service on Leatherstocking Council. 09/01/20 KAD PHASE1 Review multiple emails from Vanessa 0.10 19.00 Savoy regarding month-end reporting and changes to Riskonnect. 09/01/20 KAD PHASE1 Search BSA's internal files for alleged 0.20 38.00 perpetrator Francis McCourt. 09/01/20 KAD PHASE1 Email exchange with Anna Kutz 0.10 19.00 regarding new lawsuit filed in AR by Clifton Colwell. Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 8 of 79
Page 7 10/20/20 Bill No. 90301668 047657.000013-BAG
Date Initials Stage Description Hours Amount 09/01/20 KAD PHASE1 Search for and retrieve copy of new 0.20 38.00 lawsuit in AR by Clifton Colwell. 09/01/20 KAD PHASE1 Email exchange with Anna Kutz 0.10 19.00 regarding new lawsuit filed by Richard McPhillips and entering same in Riskonnect. 09/01/20 KAD PHASE1 Continue revising Schedule 1 Chart 2.10 399.00 of Pending Abuse Actions. 09/01/20 KJM PHASE1 Analyze/review Arkansas Complaint 0.40 60.00 in preparation for entering new claim into Riskonnect. (Colwell, Clifton). 09/01/20 KJM PHASE1 Enter new Arkansas lawsuit into 1.00 150.00 Riskonnect in preparation for litigation per Anna Kutz request. (Colwell, Clifton). 09/02/20 BAG PHASE1 Review media coverage regarding 0.20 128.00 Clifton Colwell case in Arkansas. 09/02/20 BAG PHASE1 Review email exchanges regarding 0.20 128.00 Status Conference in John Doe v. BSA (New Mexico) and internal communications with Sean Manning regarding same. 09/02/20 SEM PHASE1 Email exchange with BSA Kansas 0.20 89.00 City employment defense counsel regarding review of BSA Electronically Stored Information procedures. 09/02/20 SEM PHASE1 Email exchange with Crossroads of 0.20 89.00 the West Council regarding merger of all Utah Councils and updated contact information. 09/02/20 SEM PHASE1 Email exchange with the Green 0.20 89.00 Mountain Council in Vermont regarding AIS claim investigation matters. 09/02/20 SEM PHASE1 Email exchange with New Mexico 0.30 133.50 defense counsel regarding upcoming status conference in the John Doe v. Richard Lucero matter and BSA positions on pending motions. Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 9 of 79
Page 8 10/20/20 Bill No. 90301668 047657.000013-BAG
Date Initials Stage Description Hours Amount 09/02/20 SEM PHASE1 Email exchange with Greater New 0.20 89.00 York Councils regarding possible phishing email related to BSA claims matters and forward same to BSA. 09/02/20 SEM PHASE1 Email exchange with New Mexico 0.20 89.00 defense counsel regarding a request from Plaintiff's counsel in the John Doe v. Richard Lucero case for production of the perpetrator's BSA internal file. 09/02/20 SEM PHASE1 Email exchange with Westark Area 0.30 133.50 Council regarding news article appearing in this morning's edition of the Arkansas Democrat Gazette about the Clifton Colwell case and review the same. 09/02/20 SEM PHASE1 Email to Arkansas defense counsel 0.10 44.50 with this morning's news story from the Arkansas Democrat Gazette about the Clifton Colwell case. 09/02/20 SEM PHASE1 Review USA Today article regarding 0.10 44.50 new BSA abuse claims advertising with quotes from plaintiff attorneys and new estimations of potential claims. 09/02/20 SEM PHASE1 Email exchange with Sidley regarding 0.20 89.00 New Mexico Plaintiff's request for a BSA internal file in the John Doe v. Lucero case. 09/02/20 SEM PHASE1 Email exchange with Arkansas 0.20 89.00 defense counsel regarding representation of the Westark Council and clearing possible conflicts with BSA. 09/02/20 SEM PHASE1 Email to Sidley regarding upcoming 0.20 89.00 Status Conference in New Mexico and BSA position on the removal pleadings filed by Plaintiff John Doe and Defendant Sacred Heart. 09/02/20 SEM PHASE1 Email from Twin Rivers Council in 0.30 133.50 New York with information and documents related to the Cliff Bourst Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 10 of 79
Page 9 10/20/20 Bill No. 90301668 047657.000013-BAG
Date Initials Stage Description Hours Amount case for confirmation of chartered organization status, review, update litigation tracking spreadsheet and forward same to BSA. 09/02/20 SEM PHASE1 Email to Sidley with update on 0.20 89.00 research related to the lawsuits filed against alleged chartered organizations without a BSA entity named for updating the Consent Order Schedules. 09/02/20 SEM PHASE1 Email to BSA with background 0.20 89.00 information and records related to the Cliff Bourst claim in New York. 09/02/20 SEM PHASE1 Email to BSA Washington D.C. 0.20 89.00 defense counsel regarding information related to plaintiffs in the multi-plaintiff John Doe case filed there. 09/02/20 SEM PHASE1 Continue reviewing BSA internal files 2.80 1,246.00 related to newly filed New York lawsuits and input data into the Litigation tracking Spreadsheet. 09/02/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 adding information to the BSA internal file of a perpetrator from a non-BSA lawsuit. 09/02/20 SEM PHASE1 Email exchange with Michigan 0.30 133.50 defense counsel regarding the settlement of the Jane Doe v. Cascade Township case and obtaining information related to the same from a Freedom of Information Act request and review Order of case dismissal. 09/02/20 SEM PHASE1 Email to BSA with Order of Dismissal 0.10 44.50 in Jane Doe v. Cascade Township case in Michigan. 09/02/20 SEM PHASE1 Review notes provided with found 0.10 44.50 BSA internal files for alleged perpetrators of Washington D.C. plaintiffs and update the John Doe 1- 8 chart accordingly. Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 11 of 79
Page 10 10/20/20 Bill No. 90301668 047657.000013-BAG
Date Initials Stage Description Hours Amount 09/02/20 KAD PHASE1 Review email from Cassandra 0.10 19.00 Malone regarding status conference on Plaintiff’s Objection to Notice of Removal and Motion to Remand (as to certain parties) and Defendant Sacred Heart-Espanola’s Motion to remand Claims. 09/02/20 KAD PHASE1 Email exchange with Nicole 0.10 19.00 Liberatore regarding notices of second stipulation and agreed order filed in 2 new, New York lawsuits. 09/02/20 KAD PHASE1 Continue revising Schedule 1 Chart 3.00 570.00 of Pending Abuse Actions. 09/02/20 KAD PHASE1 Search BSA' internal files for alleged 1.40 266.00 perpetrators named in DC lawsuit. 09/03/20 BAG PHASE1 Review email update from defense 0.10 64.00 counsel in I.G. v. Ozark Trails Council (MO). 09/03/20 BAG PHASE1 Review Complaint and service 0.50 320.00 information in John C. Doe v Western Los Angeles County Council and internal communications with Sean Manning regarding same. 09/03/20 BAG PHASE1 Review letter from coverage counsel 0.20 128.00 for Chubb in Lawson v. BSA. 09/03/20 SEM PHASE1 Email exchange with BSA insurer 0.20 89.00 Markel regarding continued stay of litigation and lack of case activity. 09/03/20 SEM PHASE1 Email exchange with Missouri 0.20 89.00 defense counsel regarding dismissal of perpetrator from the I.G. case and review same. 09/03/20 SEM PHASE1 Email to BSA with copy of dismissal 0.10 44.50 of perpetrator in the I.G. case in Missouri. 09/03/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 ability and timing of closure for the Jane Doe case in Michigan. 09/03/20 SEM PHASE1 Email exchange with Sidley regarding 0.20 89.00 confirmation of details to plan for Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 12 of 79
Page 11 10/20/20 Bill No. 90301668 047657.000013-BAG
Date Initials Stage Description Hours Amount response to motions to remand in the John Doe v. Richard Lucero matter in New Mexico. 09/03/20 SEM PHASE1 Email to New Mexico defense 0.10 44.50 counsel advising to proceed with plan on BSA positions to remand motions in the John Doe (NM) matter. 09/03/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 information obtained from the Twin Rivers Council related to recently received lawsuits. 09/03/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 service of process on the Western Los Angeles County Council in the John C. Doe case. 09/03/20 SEM PHASE1 Email exchange with Western Los 0.20 89.00 Angeles County Council regarding court filed pleadings related to change in judges. 09/03/20 SEM PHASE1 Email to California defense counsel 0.10 44.50 with pleadings received by the Western Los Angeles County Council regarding change of judge assignment in the John C. Doe matter. 09/03/20 SEM PHASE1 Email exchange with the Greater 0.20 89.00 Niagara Frontier Council regarding documents collected related to numerous new lawsuits filed against the council and best method for transmitting the same. 09/03/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 the Eric Winter case filed in New York and information received related to the same. 09/03/20 SEM PHASE1 Telephone call from BSA regarding 0.20 89.00 historic Chippewa Valley Council matter that was called into BSA. 09/03/20 SEM PHASE1 Further email discussion with BSA 0.30 133.50 regarding additional recently filed New York lawsuits and information Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 13 of 79
Page 12 10/20/20 Bill No. 90301668 047657.000013-BAG
Date Initials Stage Description Hours Amount obtained regarding the same. 09/03/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 the handling of unverifiable claims. 09/03/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding M.G. pre-litigation claim. 09/03/20 KAD PHASE1 Review court's order requiring 0.10 19.00 dismissal papers from counsel for settlement in Jane Doe v. Cascade Township case. 09/03/20 KAD PHASE1 Review email and documents from 0.10 19.00 Anna Kutz regarding judge's recusal in John C Doe lawsuit. 09/03/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding Eric Winter lawsuit. 09/03/20 KAD PHASE1 Review plaintiff's dismissal against 0.10 19.00 the alleged perpetrator in I.G. (MO) case. 09/03/20 KAD PHASE1 Continue revising Schedule 1 Chart 6.60 1,254.00 of Pending Abuse Actions. 09/03/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding Winton Brown lawsuit and request for information to the Council regarding same. 09/03/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding lawsuit filed by S.C. and request for information to the Council regarding same. 09/04/20 BAG PHASE1 Review new M.F. Complaint filed in 0.30 192.00 NJ and internal communications with Sean Manning regarding same. 09/04/20 BAG PHASE1 Review media coverage regarding 0.20 128.00 Nevada claims and exchange email with Anna Kutz regarding same. 09/04/20 BAG PHASE1 Review message from Local Council 0.20 128.00 regarding notice procedures. 09/04/20 SEM PHASE1 Email exchange with Pennsylvania 0.20 89.00 defense counsel regarding the M.F. case filed in New Jersey. Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 14 of 79
Page 13 10/20/20 Bill No. 90301668 047657.000013-BAG
Date Initials Stage Description Hours Amount 09/04/20 SEM PHASE1 Email exchange with New Jersey 0.20 89.00 defense counsel regarding the M.F. case filed in New Jersey. 09/04/20 SEM PHASE1 Email to BSA to alert of new lawsuit 0.20 89.00 filed in New Jersey for M.F. and discuss assignment of same to New Jersey defense counsel. 09/04/20 SEM PHASE1 Email to Pennsylvania defense 0.10 44.50 counsel advising of assignment of new M.F. case in New Jersey to New Jersey defense counsel. 09/04/20 SEM PHASE1 Email to New Jersey defense counsel 0.20 89.00 to assign newly filed M.F. case in New Jersey with directions on responding to the same. 09/04/20 SEM PHASE1 Review new complaint filed in New 0.30 133.50 Jersey for M.F. and summarize same for Northern New Jersey Council. 09/04/20 SEM PHASE1 Email to Northern New Jersey 0.20 89.00 Council with new M.F. lawsuit, facts of the same, defense actions, and request for records. 09/04/20 SEM PHASE1 Review news article from Las Vegas, 0.80 356.00 Nevada regarding two BSA abuse Plaintiff's, research pending master claims spreadsheet to attempt to identify claimants, and send article and analysis to BSA. 09/04/20 SEM PHASE1 Email from Northern New Jersey 0.10 44.50 Council with initial information related to new M.F. case. 09/04/20 SEM PHASE1 Email from New Jersey defense 0.20 89.00 counsel with Plaintiff M.F.'s real name and forward same to BSA. 09/04/20 SEM PHASE1 Email to Northern New Jersey 0.10 44.50 Council with identity of Plaintiff M.F. for records search. 09/04/20 SEM PHASE1 Request a copy of the BSA internal 0.10 44.50 file for the perpetrator in the new M.F. case filed in New Jersey for review and research into claims and records Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 15 of 79
Page 14 10/20/20 Bill No. 90301668 047657.000013-BAG
Date Initials Stage Description Hours Amount related to the same. 09/04/20 SEM PHASE1 Email from BSA Regarding the Las 0.10 44.50 Vegas claimant news article and a response to the local council regarding the same. 09/04/20 SEM PHASE1 Review weekly new claims report 0.10 44.50 prepared by Kelci Davis to ensure all new claims have been addressed. 09/04/20 SEM PHASE1 Review email exchanges and 0.10 44.50 information from BSA regarding the Philip Johnson claim from the Chippewa Valley Council. 09/04/20 SEM PHASE1 Review email from Transatlantic 0.20 89.00 Council regarding BSA abuse advertising message and forward same to BSA. 09/04/20 SEM PHASE1 Email advising there is no BSA 0.20 89.00 internal file for the perpetrator in the new M.F. case filed in New Jersey and notify BSA team of the same. 09/04/20 SEM PHASE1 Email to Sidley regarding updated 0.10 44.50 Consent Order Schedules. 09/04/20 SEM PHASE1 Email exchange with Washington 0.20 89.00 D.C. defense counsel regarding information needed for investigation of John Doe 1-8 claims. 09/04/20 SEM PHASE1 Review Master Record of Greater 0.90 400.50 Niagara Frontier Council Lawsuits sent from New York council and update litigation tracking chart with the information from the same. 09/04/20 SEM PHASE1 Email to BSA with Master Record of 0.10 44.50 Greater Niagara Frontier Council Lawsuits and information related to the same. 09/04/20 SEM PHASE1 Email to Greater Niagara Frontier 0.10 44.50 Council seeking additional information related to a particular perpetrator on the spreadsheet they sent. Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 16 of 79
Page 15 10/20/20 Bill No. 90301668 047657.000013-BAG
Date Initials Stage Description Hours Amount 09/04/20 SEM PHASE1 Review additionally located BSA 0.40 178.00 internal file for alleged New York perpetrator in the Kaufman case. 09/04/20 SEM PHASE1 Email request from BSA regarding 0.30 133.50 information received from the Westchester-Putnam council about the S.C. case, research information and forward same to BSA. 09/04/20 SEM PHASE1 Email request from BSA regarding 0.30 133.50 information received from the Greater New York Council about the Winter case, research information and forward same to BSA. 09/04/20 SEM PHASE1 Email from Greater New York Council 0.20 89.00 advising they cannot confirm status of certain alleged chartered organizations and update litigation tracking chart. 09/04/20 SEM PHASE1 Review information received from 0.20 89.00 Greater New York Councils regarding new lawsuit filed for Durlachen and update litigation tracking spreadsheet with the same. 09/04/20 SEM PHASE1 Email from Greater New York 0.30 133.50 Councils with information and records related to the recently filed and served JMBX1 Doe case, review same and update the litigation tracking spreadsheet. 09/04/20 SEM PHASE1 Email to BSA with information 0.10 44.50 received from Greater New York Councils in regard to the JMBX1 Doe case. 09/04/20 SEM PHASE1 Email from the Greater New York 0.30 133.50 Councils with service of process documents in the JMBX1 Doe case, review and forward same to New York defense counsel. 09/04/20 KAD PHASE1 Prepare weekly new claims report. 2.30 437.00 09/04/20 KAD PHASE1 Email Sidley Austin, Alvarez Marsal, 0.10 19.00 BSA and Monica Blacker regarding Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 17 of 79
Page 16 10/20/20 Bill No. 90301668 047657.000013-BAG
Date Initials Stage Description Hours Amount weekly new abuse claims report. 09/04/20 KAD PHASE1 Finish revising Schedule 1 Chart of 3.70 703.00 Pending Abuse Actions. 09/04/20 KAD PHASE1 Email exchange with Anna Kutz 0.10 19.00 regarding new lawsuit filed in New Jersey by M.F. 09/04/20 KAD PHASE1 Email William Curtain and Andres 0.10 19.00 Barajas regarding revised schedule 1 chart of pending abuse actions. 09/04/20 KAD PHASE1 Search BSA's internal files for alleged 0.20 38.00 perpetrator, Robert Svec, named in M.F. (NJ) lawsuit. 09/08/20 BAG PHASE1 Review plaintiff's Motion to Compel in 0.30 192.00 John Doe (NM) v BSA. 09/08/20 BAG PHASE1 Review email from defense counsel 0.20 128.00 in JA-009 Doe regarding Dad's Club of Troop One and internal communications with Sean Manning regarding same. 09/08/20 SEM PHASE1 Review BSA internal files for 1.00 445.00 Washington DC perpetrators and update information derived from same on the case tracking spreadsheet. 09/08/20 SEM PHASE1 Email and telephone call with 0.20 89.00 Washington DC defense counsel regarding sharing litigation tracking chart information with Plaintiff's counsel when seeking information related to Plaintiff John Does 1-8. 09/08/20 SEM PHASE1 Email exchange with New York 0.30 133.50 defense counsel regarding representation of chartered organization in the JA-009 Doe case and review documents related to the same. 09/08/20 SEM PHASE1 Continue revising Master Claims 0.30 133.50 Valuation Spreadsheet to add more valuations to recent claims and cases. Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 18 of 79
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Date Initials Stage Description Hours Amount 09/08/20 SEM PHASE1 Email from New Mexico defense 0.30 133.50 counsel with Plaintiff’s Motion to Compel Compliance with the Court’s Order of August 27, 2020 and Request for Hearing regarding same in the John Doe (NM) v. Lucero mater and review both. 09/08/20 SEM PHASE1 Email exchange with Greater Niagara 0.20 89.00 Frontier Council regarding service of process in the LG-81 Doe and LG-63 Doe cases. 09/08/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding JMBX1 Doe lawsuit. 09/08/20 KAD PHASE1 Review email exchange between 0.10 19.00 Sean Manning and Laura Steel regarding John Doe 1-8 (DC) lawsuit and plaintiff's request for information. 09/08/20 KAD PHASE1 Review plaintiffs' disclosure of 0.10 19.00 identities of John Does 1-8 (DC). 09/08/20 KAD PHASE1 Chatter BSA regarding updates made 0.10 19.00 to claim records for John Does 1-8 (DC). 09/08/20 KAD PHASE1 Update John Does 1-8 (DC) claim 0.50 95.00 records in Riskonnect with plaintiffs' identities, addresses and Local Council information. 09/08/20 KAD PHASE1 Review email exchange between 0.10 19.00 Sean Manning and Michael Kenny regarding representation of the chartered organization named in JA- 009 Doe lawsuit. 09/08/20 KAD PHASE1 Analyze lawsuit filed by AB 426 Doe 0.20 38.00 in preparation of entering same in Riskonnect. 09/08/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by AB 426 Doe. 09/09/20 BAG PHASE1 Review media coverage regarding 0.20 128.00 bankruptcy status and developments and internal communications with Sean Manning regarding same. Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 19 of 79
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Date Initials Stage Description Hours Amount 09/09/20 BAG PHASE1 Review multiple emails in Longhouse 0.30 192.00 Council cases and attention to same. 09/09/20 BAG PHASE1 Review complaint in Doe v City of 0.50 320.00 Rye (NY) and internal communications with Sean Manning and Kelci Davis regarding same. 09/09/20 BAG PHASE1 Review complaints received during 2.00 1,280.00 weeks of September 1 and September 8 and internal team meeting to discuss pending claims and cases. 09/09/20 SEM PHASE1 Review Law 360 article regarding 0.30 133.50 fighting between claimant groups in the BSA bankruptcy and effect on case and forward same to BSA. 09/09/20 SEM PHASE1 Email from BSA with service of 0.10 44.50 process in the City of Rye contribution lawsuit. 09/09/20 SEM PHASE1 Review third-party complaint filed in 0.80 356.00 New York by the City of Rye seeking contribution from BSA and the Westchester Putnam Council and the underlying complaint filed by John Doe against the City of Rye and research facts of the same. 09/09/20 SEM PHASE1 Request for BSA internal file on the 0.10 44.50 alleged perpetrator in the lawsuit underlying the contribution claim by the City of Rye. 09/09/20 SEM PHASE1 Review Affidavit of Service on the 0.10 44.50 Greater New York Councils in the Wilberto Melendez case. 09/09/20 SEM PHASE1 Review BSA internal file for 0.20 89.00 perpetrator in the underlying case against the City of Rye in New York for connection to BSA. 09/09/20 SEM PHASE1 Email to BSA with analysis of new 0.20 89.00 City of Rye case filed in New York and details of the same. 09/09/20 SEM PHASE1 Review affidavit of service on the 0.10 44.50 Suffolk County Council in the Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 20 of 79
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Date Initials Stage Description Hours Amount Kenneth Krummenacker case. 09/09/20 SEM PHASE1 Email to Westchester-Putnam 0.20 89.00 Council in New York with information related to service of process in the City of Rye case and seek information regarding the same. 09/09/20 SEM PHASE1 Email to New York defense counsel 0.20 89.00 with information related to the service of process in the LG-81 Doe and LG- 63 Doe cases on the Greater Niagara Frontier Council. 09/09/20 SEM PHASE1 Email to BSA with updated 0.20 89.00 information related to the LG-63 Doe case received from the Greater Niagara Frontier Council in New York and update litigation tracking chart with the same. 09/09/20 SEM PHASE1 Email to the Suffolk County Council in 0.20 89.00 New York with Affidavit of Service and request for service of process documents in the Kenneth Krummenacker case. 09/09/20 SEM PHASE1 Email to the Greater New York 0.10 44.50 Councils in New York with Affidavit of Service and request for service of process documents in the Wilberto Melendez case. 09/09/20 SEM PHASE1 Email to Sidley regarding new third- 0.20 89.00 party case filed against the BSA and Westchester Putnam Council by the City of Rye and seek direction on the same. 09/09/20 SEM PHASE1 Review several emails from the 0.50 222.50 Longhouse Council with correspondence from multiple insurers of the Roman Catholic Diocese of Syracuse related to several lawsuits pending against the Council and their denial of coverage, review same and forward to BSA. 09/09/20 SEM PHASE1 Email exchange with Westchester- 0.20 89.00 Putnam Council in New York Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 21 of 79
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Date Initials Stage Description Hours Amount regarding the City of Rye complaint and related case. 09/09/20 SEM PHASE1 Additional email correspondence with 0.30 133.50 the Westchester-Putnam Council regarding the City of Rye complaint and underlying John Doe claim and details of both. 09/09/20 SEM PHASE1 Email exchange with Longhouse 0.30 133.50 Council regarding service of process in the John Doe 2020-0655 case and review same. 09/09/20 SEM PHASE1 Email to New York defense counsel 0.10 44.50 with notice of service of process on the Longhouse Council in the John Doe case. 09/09/20 SEM PHASE1 Review emails from General Star 0.20 89.00 insurance seeking certain complaints and review information in response to the same. 09/09/20 SEM PHASE1 Review additional email from General 0.10 44.50 Star regarding general policy review for certain excess BSA claims. 09/09/20 SEM PHASE1 Locate and review prior lawsuit by 0.50 222.50 John Doe against BSA and the Westchester-Putnam Council related to the City of Rye Complaint for Contribution and send same to Sidley team and BSA. 09/09/20 SEM PHASE1 Email exchange with Kentucky 0.30 133.50 defense counsel and Clint Scharff regarding getting revised deposition dates form his deposition in the LFL cases. 09/09/20 SEM PHASE1 Review service of process documents 0.40 178.00 from today and send same to appropriate New York defense counsel. 09/09/20 SEM PHASE1 Revise and update Washington, D.C. 0.30 133.50 multi-plaintiff lawsuit data chart with information received from Plaintiff's counsel about the Plaintiffs' real Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 22 of 79
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Date Initials Stage Description Hours Amount identities and send same to BSA. 09/09/20 SEM PHASE1 Review Defendant Kallaad Watkins 0.50 222.50 Cepada's Motion to Dismiss for Lack of In Personam Jurisdiction in the Pedro Luis Lopez case in New Jersey and send summary of the same to BSA. 09/09/20 SEM PHASE1 Continue to revise Master Claims 0.50 222.50 Spreadsheet with valuations of recent claims. 09/09/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding lawsuit filed in 2015 by S.G. 09/09/20 KAD PHASE1 Review John Doe NM's Motion to 0.20 38.00 Compel Compliance with the Court’s Order of August 27, 2020, a Request for Hearing, and an email from Kathleen Russell regarding same. 09/09/20 KAD PHASE1 Update DC lawsuit claims on master 0.50 95.00 claims spreadsheet with plaintiffs' identities and Local Council information. 09/09/20 KAD PHASE1 Create new claim in Riskonnect for 0.90 171.00 lawsuit filed by AB 427 Doe. 09/09/20 KAD PHASE1 Analyze lawsuit filed by AB 427 Doe 0.20 38.00 in preparation of entering same in Riskonnect. 09/09/20 KAD PHASE1 Analyze lawsuit filed by John Doe 4 0.20 38.00 B.C. in preparation of entering same in Riskonnect. 09/09/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by John Doe 4 B.C. 09/09/20 KAD PHASE1 Analyze lawsuit filed by John Doe 6 0.20 38.00 J.B. in preparation of entering same in Riskonnect. 09/09/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by John Doe 6 J.B. 09/09/20 KAD PHASE1 Search BSA's internal files for alleged 0.30 57.00 perpetrators named in OCVAWCM- Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 23 of 79
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Date Initials Stage Description Hours Amount Doe lawsuit. 09/09/20 KAD PHASE1 Review email from Anna Kutz 0.10 19.00 regarding new third-party Complaint filed by OCVAWCM-Doe. 09/09/20 KAD PHASE1 Analyze lawsuit filed by John Doe 7 0.20 38.00 L.B. in preparation of entering same in Riskonnect. 09/09/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by John Doe 7 L.B. 09/09/20 KAD PHASE1 Review email from Anna Kutz 0.10 19.00 regarding completion of service of process on BSA National in John Doe (Cayuga County) lawsuit. 09/09/20 KAD PHASE1 Review email from Anna Kutz 0.10 19.00 regarding completion of service of process on BSA National in John Doe (400066) case. 09/09/20 KAD PHASE1 Review email from Anna Kutz 0.10 19.00 regarding completion of service of process on BSA National in John Doe (905302-20) lawsuit. 09/09/20 KAD PHASE1 Analyze lawsuit filed by John Doe 9 0.20 38.00 G.C. in preparation of entering same in Riskonnect. 09/09/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by John Doe 9 G.C. 09/09/20 KAD PHASE1 Email exchange with Gary Seligman 0.10 19.00 at General Star regarding John Doe 34 C.P. lawsuit. 09/09/20 KAD PHASE1 BSA team meeting to discuss status 0.50 95.00 of all claims and strategy for handling same. 09/10/20 BAG PHASE1 Review chart identifying claims and 0.50 320.00 cases by state and attention to same. 09/10/20 BAG PHASE1 Telephone conference with Attorney 0.30 192.00 Paul Mones regarding New York claims and follow up email exchange with Mr. Mones and his co-counsel regarding same. Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 24 of 79
Page 23 10/20/20 Bill No. 90301668 047657.000013-BAG
Date Initials Stage Description Hours Amount 09/10/20 SEM PHASE1 Email exchange with local Arkansas 0.20 89.00 defense counsel regarding further action on the Clifton Colwell case. 09/10/20 SEM PHASE1 Review chart created by Kelci Davis 0.10 44.50 breaking down the total number of cases per state. 09/10/20 SEM PHASE1 Review second chart of break down 0.10 44.50 of all claims and cases currently pending against the BSA created by Kelci Davis. 09/10/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 new information to add to Youth Protection Timeline for 2020 and review the same. 09/10/20 SEM PHASE1 Revise BSA Youth Protection 0.60 267.00 Timeline with information received from BSA. 09/10/20 SEM PHASE1 Draft and send emails to local 1.00 445.00 councils seeking information and documents related to AIS claims with identified perpetrators not found in the BSA internal files. 09/10/20 SEM PHASE1 Continue evaluating AIS group claims 1.80 801.00 that have identified perpetrators without BSA internal files and continue adding those claims with sufficient details to the individual council claims chart for follow-up with those councils. 09/10/20 SEM PHASE1 Draft and send emails to local 1.00 445.00 councils beginning with the letter "L" seeking information related to AIS claims presented with known alleged perpetrators without BSA internal files to seek supporting documents and information related to the same. 09/10/20 SEM PHASE1 Telephone call with Greater New 0.20 89.00 York Councils regarding personal service of 13 new lawsuits today at the Scout Executive's home and further action on the same. Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 25 of 79
Page 24 10/20/20 Bill No. 90301668 047657.000013-BAG
Date Initials Stage Description Hours Amount 09/10/20 SEM PHASE1 Additional email exchange with BSA 0.20 89.00 regarding Youth Protection Timeline information. 09/10/20 SEM PHASE1 Review news article regarding court 0.20 89.00 order for bankruptcy claimants' counsel to release fee and client information and forward same to BSA. 09/10/20 SEM PHASE1 Review news article regarding BSA 0.20 89.00 lawyers entering into an agreement with claimants' counsel regarding advertising parameters and send same to BSA. 09/10/20 SEM PHASE1 Review email exchange between 0.30 133.50 Paul Mones and Bruce Griggs regarding several cases for stipulation of service, research New York litigation tracking chart for information about said assignments and respond to request from Bruce Griggs regarding the same. 09/10/20 SEM PHASE1 Email from claimant's counsel with 0.20 89.00 letter of representation for A.A. (CA) against the Ventura County Council in California. 09/10/20 SEM PHASE1 Email from claimant's counsel with 0.20 89.00 letter of representation for E.R. (NY) against the Greater New York Councils. 09/10/20 SEM PHASE1 Email exchange with the Theodore 0.40 178.00 Roosevelt Council regarding service in four lawsuits today, review of the same and revise the New York litigation tracking chart. 09/10/20 SEM PHASE1 Email from BSA advising to request 0.10 44.50 claimant fee and client declarations from Sidley. 09/10/20 SEM PHASE1 Email exchange with Istrouma Area 0.20 89.00 Council regarding investigation into AIS claims. 09/10/20 SEM PHASE1 Email to Ventura County Council in 0.30 133.50 Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 26 of 79
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Date Initials Stage Description Hours Amount California regarding new A.A. (CA) claim and handling of the same. 09/10/20 SEM PHASE1 Email to Greater New York Councils 0.20 89.00 regarding new E.R. (NY) claim and handling of the same. 09/10/20 SEM PHASE1 Email to New York defense counsel 0.20 89.00 regarding service of process of four recently filed lawsuits on the Theodore Roosevelt Council and directions to file the Notice of Stay of Litigation in the same. 09/10/20 SEM PHASE1 Email to Sidley requesting claimant 0.10 44.50 counsel disclosures related to clients and fees once they are provided by the court or unsealed. 09/10/20 SEM PHASE1 Email from Greater New York 0.10 44.50 Councils advising they have sent 13 newly served lawsuits to Ogletree via UPS. 09/10/20 KAD PHASE1 Calculate the total number of abuse 1.80 342.00 lawsuits filed in each state and prepare a chart of same per Anna Kutz request. 09/10/20 KAD PHASE1 Calculate claim data and prepare a 1.60 304.00 report of same for attorney in preparation of discussing same with client. 09/10/20 KAD PHASE1 Analyze lawsuit filed by John Doe 11 0.20 38.00 D.R. in preparation of entering same in Riskonnect. 09/10/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by John Doe 11 D.R. 09/10/20 KAD PHASE1 Analyze lawsuit filed by John Doe 13 0.20 38.00 H.D. in preparation of entering same in Riskonnect. 09/10/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by John Doe 13 H.D. 09/10/20 KAD PHASE1 Analyze three news articles regarding 0.30 57.00 deal on ads aimed at sex abuse survivors, issues between insurer and Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 27 of 79
Page 26 10/20/20 Bill No. 90301668 047657.000013-BAG
Date Initials Stage Description Hours Amount the victims' coalition, and court's order for the coalition to release documents. 09/10/20 KAD PHASE1 Begin manipulating and merging 1.40 266.00 claim valuation data from attorney into master claims tracking spreadsheet. 09/11/20 BAG PHASE1 Review/analyze new claims 0.50 320.00 spreadsheet. 09/11/20 SEM PHASE1 Email exchange with LaSalle Council 0.20 89.00 regarding information related to AIS claims with identified perpetrators without BSA internal files. 09/11/20 SEM PHASE1 Email exchange with Indian Nations 0.30 133.50 Council regarding "neighborhood patrol" designation for 1968 Scout unit at issue in AIS claim and review roster from the same. 09/11/20 SEM PHASE1 Review information and rosters 0.50 222.50 received from Indian Nations Council in regard to AIS claims. 09/11/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 the new E.R. (NY) claim in New York. 09/11/20 SEM PHASE1 Email to Pathways to Adventure 0.20 89.00 Council with AIS claim reassigned from LaSalle Council. 09/11/20 SEM PHASE1 Revise Master Claims Valuation 2.00 890.00 Spreadsheet to include new valuations for 62 new claims received. 09/11/20 SEM PHASE1 Email from New Jersey defense 0.30 133.50 counsel with Court order staying the Pedro Lopez case, review said order and forward same to BSA. 09/11/20 SEM PHASE1 Email with Sidley regarding Craig 0.30 133.50 Bleau case in New York with details on the case background and review the same prior to sending. 09/11/20 SEM PHASE1 Review Motion to Dismiss C.B. case 0.20 89.00 in New York by Hepburn Library of Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 28 of 79
Page 27 10/20/20 Bill No. 90301668 047657.000013-BAG
Date Initials Stage Description Hours Amount Waddinton. 09/11/20 SEM PHASE1 Email exchange with Sidley regarding 0.20 89.00 City of Rye claim for contribution and need to further discuss the same. 09/11/20 SEM PHASE1 Review Weekly New Claims Report 0.10 44.50 prepared by Kelci Davis to ensure all new claims received this week have been handled. 09/11/20 SEM PHASE1 Email exchange with Sidley regarding 0.30 133.50 chartered organization status of named defendants in the C.B. case in New York and forward same request to the Longhouse Council for confirmation of the same. 09/11/20 SEM PHASE1 Continue to review spreadsheet of 1.20 534.00 AIS and other claims that identify perpetrators without BSA internal files and collecting data to send to local councils seeking additional information to help create the same. 09/11/20 SEM PHASE1 Email exchange with Boston 0.20 89.00 claimant's counsel regarding new claims for R.S. in Ohio and M.R. in New York. 09/11/20 SEM PHASE1 Review letter of representation to the 0.40 178.00 Greater Niagara Frontier Council from Boston claimant's counsel for M.R. (NY) and forward same to council. 09/11/20 SEM PHASE1 Review letter of representation to the 0.40 178.00 Black Swamp Council from Boston claimant's counsel for R.S. (OH) and forward same to council with direction on the same. 09/11/20 SEM PHASE1 Email from the Pathway to Adventure 0.20 89.00 Council in response to request for information related to AIS case previously assigned to LaSalle Council and review roster documents received. 09/11/20 SEM PHASE1 Multi-email exchange with BSA 0.30 133.50 insurance carrier Everest regarding Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 29 of 79
Page 28 10/20/20 Bill No. 90301668 047657.000013-BAG
Date Initials Stage Description Hours Amount requests for complaints and notification of claim number changes. 09/11/20 SEM PHASE1 Begin drafting and sending emails to 0.90 400.50 local councils beginning with the letters "M" with requests for information related to AIS claims that need BSA internal files for identified perpetrators. 09/11/20 SEM PHASE1 Email exchange with Black Swamp 0.20 89.00 Area Council in Ohio regarding details of the R.S. claim and service issues. 09/11/20 SEM PHASE1 Email exchange with the Los Padres 0.20 89.00 Council in California with information related to AIS claims and BSA internal creation matters and review the same. 09/11/20 KAD PHASE1 Review letter of representation 0.10 19.00 regarding A.A. pre-litigation claim in CA. 09/11/20 KAD PHASE1 Review letter of representation 0.10 19.00 regarding E.R. pre-litigation claim in New York. 09/11/20 KAD PHASE1 Email Sidley Austin, Alvarez Marsal, 0.10 19.00 BSA and Monica Blacker regarding weekly new abuse claims report. 09/11/20 KAD PHASE1 Prepare weekly new claims report. 1.00 190.00 09/11/20 KAD PHASE1 Finish manipulating and merging 1.00 190.00 claim valuation data from attorney into master claims tracking spreadsheet. 09/11/20 KAD PHASE1 Prepare report of 62 new claims to 1.40 266.00 assist attorney with valuing same. 09/11/20 KAD PHASE1 Email exchange with Anna Kutz 0.10 19.00 regarding service of process completed on Theodore Roosevelt Council for 4 New York lawsuits. 09/11/20 KAD PHASE1 Update Thomas Ellison claim record 0.10 19.00 in Riskonnect to reflect completion of service on Theodore Roosevelt Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 30 of 79
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Date Initials Stage Description Hours Amount Council per Anna Kutz request. 09/11/20 KAD PHASE1 Update Chris Croce claim record in 0.10 19.00 Riskonnect to reflect completion of service on Theodore Roosevelt Council per Anna Kutz request. 09/11/20 KAD PHASE1 Update John Croce claim record in 0.10 19.00 Riskonnect to reflect completion of service on Theodore Roosevelt Council per Anna Kutz request. 09/11/20 KAD PHASE1 Update Daniel Duffey claim record in 0.10 19.00 Riskonnect to reflect completion of service on Theodore Roosevelt Council per Anna Kutz request. 09/11/20 KAD PHASE1 Analyze lawsuit filed by John Doe 15 0.20 38.00 T.H. in preparation of entering same in Riskonnect. 09/11/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by John Doe 15 T.H. 09/11/20 KAD PHASE1 Analyze lawsuit filed by John Doe 17 0.20 38.00 R.H. in preparation of entering same in Riskonnect. 09/11/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by John Doe 17 R.H. 09/11/20 KAD PHASE1 Conference call with Heidi Steppe 0.40 76.00 regarding reports needed to reflect alleged perpetrators not in BSA's internal files. 09/14/20 BAG PHASE1 Internal team meeting to discuss new 1.00 640.00 claims and overall status. 09/14/20 SEM PHASE1 Email exchange with Middle 0.30 133.50 Tennessee Council attorney regarding AIS claims and investigations into the same. 09/14/20 SEM PHASE1 Email from Middle Tennessee 0.10 44.50 Council regarding initial investigation into AIS claim request. 09/14/20 SEM PHASE1 Email exchange with Longs Peak 0.30 133.50 Council regarding information related to AIS claim investigation and review Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 31 of 79
Page 30 10/20/20 Bill No. 90301668 047657.000013-BAG
Date Initials Stage Description Hours Amount the same. 09/14/20 SEM PHASE1 Email exchange with Golden Spread 0.40 178.00 Council regarding information related to the New Jersey multi-Plaintiff lawsuit, review said records, update tracking chart with the same and send information to BSA. 09/14/20 SEM PHASE1 Conference call with Sidley regarding 0.30 133.50 handling of third-party cases for chartered organizations in cases without a BSA defendant like the City of Rye and C.B. in New York. 09/14/20 SEM PHASE1 Review multiple emails with 0.20 89.00 correspondence from Axis Insurance denying coverage for 95 claims. 09/14/20 SEM PHASE1 Email exchange with Black Swamp 0.20 89.00 Area Council regarding additional investigation into new R.S. (OH) claim. 09/14/20 SEM PHASE1 Email exchange with Lake Erie 0.30 133.50 Council regarding investigation results from AIS claims and review the same. 09/14/20 SEM PHASE1 Email exchange with attorney for the 0.20 89.00 Mobile Area Council regarding AIS claims investigation information and need to forward same to a different council in Louisiana. 09/14/20 SEM PHASE1 Email to Denver Area Council with 0.20 89.00 claim previously sent to Longs Peak Council with information related to the same and request for information. 09/14/20 SEM PHASE1 Research proper council information 0.30 133.50 and send email to the same regarding alleged perpetrator Francis Tinker previously assigned to Mobile Area Council and request information related to the same. 09/14/20 SEM PHASE1 Telephone call from and email follow- 0.20 89.00 up to Southern Louisiana Council regarding AIS claim investigation and Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 32 of 79
Page 31 10/20/20 Bill No. 90301668 047657.000013-BAG
Date Initials Stage Description Hours Amount lack of records due to flood. 09/14/20 SEM PHASE1 Review BSA internal for Francis 0.20 89.00 "Frank" Tinker from Louisiana and update Master Claims Spreadsheet information. 09/14/20 SEM PHASE1 Email exchange with New Mexico 0.20 89.00 defense counsel regarding orders on various motions to remove underlying proceedings in John Doe (NM) cases. 09/14/20 SEM PHASE1 Continue to review Master Claims 3.50 1,557.50 Spreadsheet of AIS and other group claims with identified perpetrators without BSA internal files and gather data for further follow-up with the local councils. 09/14/20 SEM PHASE1 Review email and attached report 0.20 89.00 from Berkley Insurance Company regarding denial of coverage and notice to claimants in New York claims. 09/14/20 SEM PHASE1 Review email correspondence from 0.10 44.50 AIG regarding acknowledgment of 44 claims from multiple states. 09/14/20 SEM PHASE1 Email from Sidley regarding setting a 0.10 44.50 conference call with Wiggin and Dana in New York to discuss City of Rye third-party complaint. 09/14/20 SEM PHASE1 Review minute order from court 0.10 44.50 received from New Mexico defense counsel regarding Motions to Transfer in the John Doe (NM) matter. 09/14/20 SEM PHASE1 Email exchange with Laurel 0.20 89.00 Highlands Council regarding multiple emails with information and documents related to recent lawsuits filed against the council. 09/14/20 SEM PHASE1 Email exchange with Kentucky 0.30 133.50 defense counsel and LFL regarding setting the deposition of Tim Anderson. Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 33 of 79
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Date Initials Stage Description Hours Amount 09/14/20 SEM PHASE1 Email from Connecticut Rivers 0.10 44.50 Council to Narragansett Council forwarding a request for information related to an AIS claim. 09/14/20 SEM PHASE1 Email exchange with the Northern 0.20 89.00 New Jersey Council regarding information related to the M.F. case from 1962. 09/14/20 SEM PHASE1 Email exchange with Kansas City 0.20 89.00 employment defense counsel regarding email received suggesting a download link from BSA and seeking confirmation of the same. 09/14/20 KAD PHASE1 Review email from Cassandra 0.10 19.00 Malone regarding summary of status hearing in John Doe (NM) v. BSA. 09/14/20 KAD PHASE1 Begin preparing reports for Heidi 6.00 1,140.00 Steppe that identity alleged perpetrators, from active and settled claims, not in BSA's internal files. 09/14/20 KAD PHASE1 Email exchange with Kathleen 0.10 19.00 Russell regarding clerk's minutes filed with the court. 09/15/20 SEM PHASE1 Extensive email to New York Defense 0.50 222.50 counsel regarding the City of Rye third-party complaint matter with history and discussion of issues on the same. 09/15/20 SEM PHASE1 Telephone call with claimant's 0.20 89.00 counsel Andrus Wagstaff regarding various notice and proof of claim matters. 09/15/20 SEM PHASE1 Receive flash drive from Greater 0.30 133.50 Niagara Frontier Council with data and records related to recently filed lawsuits against the council, briefly review the same, and email council to advise of receipt. 09/15/20 SEM PHASE1 Email exchange with BSA regarding 0.40 178.00 the first evidence of youth protection training materials and research the Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 34 of 79
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Date Initials Stage Description Hours Amount same. 09/15/20 SEM PHASE1 Extended email discussion with 0.40 178.00 Greater New York Councils and attorney for the council regarding attempted service of process on the Scout Executive's home and need to keep service going to the council office. 09/15/20 SEM PHASE1 Email exchange with the Chickasaw 0.20 89.00 Council regarding additional perpetrator information and further research request. 09/15/20 SEM PHASE1 Email exchange with Jersey Shore 0.30 133.50 Council and BSA regarding the council's request for a complete current list of lawsuits pending against the council. 09/15/20 SEM PHASE1 Email exchange with Hudson Valley 0.30 133.50 Council and BSA regarding the council's request for a complete current list of lawsuits pending against the council. 09/15/20 SEM PHASE1 Further email exchange with 0.20 89.00 claimant's counsel in Massachusetts regarding confirmation of use of most current BSA bankruptcy proof of claim form. 09/15/20 SEM PHASE1 Review information and records 0.20 89.00 received from the Black Swamp Area Council regarding the R.S. (OH) claim. 09/15/20 SEM PHASE1 Email discussion with Connecticut 0.30 133.50 Yankee Council regarding information potentially attributable to specific AIS claims and council issuance of troop numbers. 09/15/20 SEM PHASE1 Email from Jersey Shore Council 0.10 44.50 regarding lack of information related to AIS claim investigation request. 09/15/20 SEM PHASE1 Email from Chickasaw Council with 0.30 133.50 information and records related to the Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 35 of 79
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Date Initials Stage Description Hours Amount AIS claim investigation, review the same and forward to BSA. 09/15/20 SEM PHASE1 Review information received by 0.20 89.00 Washington Crossing Council in regard to request for information related to an AIS claim in New Jersey. 09/15/20 SEM PHASE1 Conference call with New York 0.30 133.50 defense counsel and Sidley regarding the handling of the City of Rye third- party lawsuit against BSA and the Westchester-Putnam Council. 09/15/20 SEM PHASE1 Review BSA internal file for Billy 0.40 178.00 Kenneth Walker for potential relationship to the multi-plaintiff lawsuit filed in New Jersey for abuse suffered outside the State of Jersey prior to 1979. 09/15/20 SEM PHASE1 Receive and review service of 0.50 222.50 process documents from the Greater New York Councils in 13 recently filed cases and send email to council advising of the same. 09/15/20 SEM PHASE1 Email to New York defense counsel 0.20 89.00 to advise of service of process on the Greater New York Councils. 09/15/20 SEM PHASE1 Email from Nevada Area Council with 0.20 89.00 information and documents related to AIS claim investigation and review the same. 09/15/20 SEM PHASE1 Email from Indian Waters Council 0.20 89.00 with information and documents related to AIS claim investigation and review the same. 09/15/20 SEM PHASE1 Email from Spirit of Adventure 0.10 44.50 Council regarding update on research into AIS claim. 09/15/20 SEM PHASE1 Email exchange with Occoneechee 0.30 133.50 Council in North Carolina regarding information and documents related to the AIS claim investigation, review Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 36 of 79
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Date Initials Stage Description Hours Amount same and forward to BSA. 09/15/20 SEM PHASE1 Review multiple emails from the 0.20 89.00 Laurel Highlands Council in response to AIS claim investigation with information and documents related to the same and review all. 09/15/20 SEM PHASE1 Telephone call with Greater New 0.10 44.50 York Councils regarding continued service of process of Scout Executive at his home. 09/15/20 KAD PHASE1 Continue preparing reports for Heidi 7.40 1,406.00 Steppe that identity alleged perpetrators, from active and settled claims, not in BSA's internal files. 09/15/20 KAD PHASE1 Email Heidi Steppe regarding status 0.10 19.00 of reports that identity alleged perpetrators not in BSA's internal files. 09/16/20 BAG PHASE1 Review Complaints and investigation 2.00 1,280.00 status of suits filed during the week of September 7 and 14. 09/16/20 SEM PHASE1 Email to New York defense counsel 0.20 89.00 regarding continued service of process of Greater New York Councils Scout Executive at his home and need to communicate with Plaintiff's counsel to stop such activity. 09/16/20 SEM PHASE1 Email from Greater New York 0.10 44.50 Councils to advise of newly served lawsuits being sent via UPS to Ogletree in Dallas. 09/16/20 SEM PHASE1 Multiple email exchanges with BSA 0.30 133.50 regarding additional material to add to the Youth Protection Timeline document. 09/16/20 SEM PHASE1 Email from BSA alerting to service of 0.20 89.00 process on the Westchester-Putnam Council in the Donald Hobbs case and review the same. 09/16/20 SEM PHASE1 Email to New York defense counsel 0.10 44.50 Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 37 of 79
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Date Initials Stage Description Hours Amount with notice of service of process in the Donald Hobbs case against the Westchester-Putnam Council. 09/16/20 SEM PHASE1 Review new youth protection 1.00 445.00 information received from BSA and revise and update BSA Youth Protection Timeline documents to include the same. 09/16/20 SEM PHASE1 Email from New York defense 0.20 89.00 counsel regarding their conversation with plaintiffs' counsel about service of process on the Greater New York Councils Scout Executive's home and forward information of same to him. 09/16/20 SEM PHASE1 Continue to review spreadsheet of 1.80 801.00 AIS and other group claims that identify a perpetrator without a BSA internal file and continue to extract data from the same to send to local councils in an effort to obtain information and documents to create the same. 09/16/20 SEM PHASE1 Email from Minsi Trails Council 0.10 44.50 advising they have no Troop 94 in their council; relevant to AIS claim investigation. 09/16/20 SEM PHASE1 Email from BSA advising of service of 0.20 89.00 letter of representation for A.A. (CA) and review of the same. 09/16/20 SEM PHASE1 Email from BSA advising of service of 0.20 89.00 a letter of representation for E.R. (NY) and review of the same. 09/16/20 SEM PHASE1 Email to BSA regarding the handling 0.10 44.50 of the A.A. (CA) and E.R. (NY) letters of representation. 09/16/20 SEM PHASE1 Email from BSA with notice of service 0.20 89.00 of process in the Russell Kaufman case in New York and review documents served. 09/16/20 SEM PHASE1 Email to New York defense counsel 0.10 44.50 with notice of service of process in Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 38 of 79
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Date Initials Stage Description Hours Amount the Russell Kaufman case on the BSA. 09/16/20 SEM PHASE1 Email exchange with BSA to discuss 0.30 133.50 search of information related to certain Leatherstocking Council cases in New York. 09/16/20 SEM PHASE1 Email exchange with Greater Niagara 0.20 89.00 Frontier Council in New York regarding lack of information related to the John Doe 61 DV case. 09/16/20 SEM PHASE1 Research Wagner and Withrow cases 0.20 89.00 in Leatherstocking Council to determine council had no information related to either and notify BSA of the same. 09/16/20 SEM PHASE1 Email from Nevada Area Council 0.20 89.00 advising units in the Lake Tahoe area prior to 1992 fell within the Golden Empire Council and then forward AIS investigation request there. 09/16/20 SEM PHASE1 Email to Sidley seeking update on 0.10 44.50 direction to produce Richard Lucero BSA internal file in New Mexico. 09/16/20 SEM PHASE1 Begin to draft emails to local councils 1.00 445.00 with names beginning with the letter "N" with AIS claim investigation requests for creation of BSA internal files. 09/16/20 SEM PHASE1 Email exchange with Northern Florida 0.30 133.50 Council regarding AIS claim investigation and history of the same from the council and review correspondence and documents attached. 09/16/20 SEM PHASE1 Email exchange with Northeast 0.20 89.00 Georgia Council regarding AIS claim assign to their council that should be re-assigned to the Atlanta Area Council. 09/16/20 SEM PHASE1 Email exchange with Missouri 0.30 133.50 defense counsel regarding court Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 39 of 79
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Date Initials Stage Description Hours Amount ordered status report in the JCH Doe case, review draft status report and approve of the same. 09/16/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding Complaint filed by Joshua Fye. 09/16/20 KAD PHASE1 Email exchange with Anna Kutz 0.10 19.00 regarding service of process on Westchester-Putnam Council in Donald Hobbs lawsuit and updating Riskonnect with same. 09/16/20 KAD PHASE1 Review email from Anna Kutz 0.10 19.00 regarding National's receipt of a letter of representation for A.A. (CA) claim. 09/16/20 KAD PHASE1 Review email from Anna Kutz 0.10 19.00 regarding service of process on National in Kaufman lawsuit. 09/16/20 KAD PHASE1 Review email from Anna Kutz 0.10 19.00 regarding National's receipt of a letter of representation for E.R. (NY) claim. 09/16/20 KAD PHASE1 Email Heidi Steppe regarding report 0.10 19.00 of settled abuse claims that identifies alleged perpetrators not in BSA's internal files. 09/16/20 KAD PHASE1 Continue preparing reports for Heidi 3.40 646.00 Steppe that identity alleged perpetrators, from active and settled claims, not in BSA's internal files. 09/17/20 BAG PHASE1 Review multiple, voluminous 0.50 320.00 coverage and acknowledgment letters received from Derek Bauer at Chubb and attention to same. 09/17/20 BAG PHASE1 Continue review and analyses of new 3.00 1,920.00 Complaints received and internal communications with S. Manning regarding same. 09/17/20 SEM PHASE1 Email from Kentucky defense counsel 0.10 44.50 to former Scout Executive of Lincoln Heritage Council with confirmation of the setting of his deposition. Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 40 of 79
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Date Initials Stage Description Hours Amount 09/17/20 SEM PHASE1 Email from Kentucky defense counsel 0.10 44.50 to current Scout Executive of Lincoln Heritage Council with confirmation of the setting of his deposition. 09/17/20 SEM PHASE1 Email from Kentucky defense counsel 0.10 44.50 to former District Executive of Lincoln Heritage Council with confirmation of the setting of his deposition. 09/17/20 SEM PHASE1 Email to Kentucky defense counsel 0.20 89.00 regarding parameters and logistics of council and LFL depositions in the Explorer case. 09/17/20 SEM PHASE1 Email to Atlanta Area Council with 0.40 178.00 AIS investigation request previously sent to the Northeast Georgia Council. 09/17/20 SEM PHASE1 Review email and correspondence 0.20 89.00 from CHUBB regarding position on first encounter agreement and coverage position for Marsh Law Firm claims in New York. 09/17/20 SEM PHASE1 Review email and correspondence 0.20 89.00 from CHUBB regarding position on first encounter agreement and coverage position for Philips Law Firm claims in New York. 09/17/20 SEM PHASE1 Review email and correspondence 0.20 89.00 from CHUBB regarding position on first encounter agreement and coverage position for Lipsitz Law Firm claims in New York. 09/17/20 SEM PHASE1 Review email and correspondence 0.20 89.00 from CHUBB regarding position on first encounter agreement and coverage position for Ronald Kim Law Firm claims in New York. 09/17/20 SEM PHASE1 Review email and correspondence 0.20 89.00 from CHUBB regarding position on first encounter agreement and coverage position for Jeff Anderson Law Firm claims in New York. Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 41 of 79
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Date Initials Stage Description Hours Amount 09/17/20 SEM PHASE1 Review email and correspondence 0.20 89.00 from CHUBB regarding position on first encounter agreement and coverage position for John C. Bobeck v. BSA case in New York. 09/17/20 SEM PHASE1 Review email and correspondence 0.20 89.00 from CHUBB regarding position on first encounter agreement and coverage position for Ingrid Kelly v. BSA case in New York. 09/17/20 SEM PHASE1 Complete sending emails to local 0.40 178.00 councils beginning with the letter "N" related to AIS claims needing BSA internal files. 09/17/20 SEM PHASE1 Review email and correspondence 0.20 89.00 from CHUBB regarding position on first encounter agreement and coverage position for Thomas Kreiser v. BSA case in New York. 09/17/20 SEM PHASE1 Review email and correspondence 0.20 89.00 from CHUBB regarding position on first encounter agreement and coverage position for Paul Tallerico v. BSA case in New York. 09/17/20 SEM PHASE1 Continue to review spreadsheet of 2.40 1,068.00 AIS claims for perpetrators needing BSA internal files and collect data for sending to local councils with requests for information. 09/17/20 SEM PHASE1 Review email and correspondence 0.20 89.00 from CHUBB regarding position on first encounter agreement and coverage position for Norman Wolfe v. BSA case in New York. 09/17/20 SEM PHASE1 Review email and correspondence 0.20 89.00 from CHUBB regarding position on first encounter agreement and coverage position for J.H. claim in New York. 09/17/20 SEM PHASE1 Email from Northern New Jersey 0.10 44.50 Council advising that one of the AIS claims assigned to their council Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 42 of 79
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Date Initials Stage Description Hours Amount should actually be assigned to the Greater New York Council. 09/17/20 SEM PHASE1 Email from Northeast Illinois Council 0.10 44.50 in response to AIS claim investigation request. 09/17/20 SEM PHASE1 Email discussion with BSA regarding 0.30 133.50 the Recker claim in Midland, Michigan. 09/17/20 SEM PHASE1 Email to Greater New York Councils 0.10 44.50 with AIS claim investigation request originally mis-assigned to Northern New Jersey. 09/17/20 SEM PHASE1 Email from Lincoln Heritage Council 0.20 89.00 in response of AIS claim investigation request and review the same. 09/17/20 SEM PHASE1 Send emails to local councils 2.50 1,112.50 beginning with the letters "O" and "P" to seek information related to AIS claims needing BSA internal files. 09/17/20 SEM PHASE1 Email from Sidley to New York 0.10 44.50 defense counsel regarding handling of a response to the City of Rye third- party complaint against BSA. 09/17/20 SEM PHASE1 Email exchange with Kentucky 0.30 133.50 defense counsel and LFL regarding information related to upcoming depositions in the LFL Explorer cases and potential topics of testimony. 09/17/20 SEM PHASE1 Email exchange with Greater Niagara 0.20 89.00 Frontier Council regarding service of process in the Christopher Klink case and theories about the claim and effect on council in bankruptcy. 09/17/20 SEM PHASE1 Email exchange with Kentucky 0.20 89.00 defense counsel with information related to evidence found related to LFL cases. 09/17/20 SEM PHASE1 Email from Pee Dee Area Council 0.20 89.00 with information related to AIS claim investigation and review the same. Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 43 of 79
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Date Initials Stage Description Hours Amount 09/17/20 SEM PHASE1 Email from Mid-America Council with 0.20 89.00 information and documents related to AIS claims investigation and review the same. 09/17/20 SEM PHASE1 Email from BSA with notice of service 0.10 44.50 of process in the Robert Stillman v. Westchester-Putnam Council case. 09/17/20 SEM PHASE1 Email to New York defense counsel 0.10 44.50 with notice of service of process in the Robert Stillman v. Westchester- Putnam Council case. 09/17/20 KAD PHASE1 Analyze lawsuit filed by John Doe 18 0.20 38.00 J.D. in preparation of entering same in Riskonnect. 09/17/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by John Doe 18 J.D. 09/17/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding S.D. (MA) claim. 09/17/20 KAD PHASE1 Email exchange with Anna Kunts 0.10 19.00 regarding tracking Local Council changes. 09/17/20 KAD PHASE1 Analyze lawsuit filed by John Doe 19 0.20 38.00 J.M. in preparation of entering same in Riskonnect. 09/17/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by John Doe 19 J.M. 09/17/20 KAD PHASE1 Email Heidi Steppe regarding 0.10 19.00 completion of reports that identify alleged perpetrators not in BSA's internal files. 09/17/20 KAD PHASE1 Finish preparing reports for Heidi 5.00 950.00 Steppe that identity alleged perpetrators, from active and settled claims, not in BSA's internal files. 09/18/20 SEM PHASE1 Telephone call with Westark Council 0.10 44.50 regarding service of process issues in the Colwell case. 09/18/20 SEM PHASE1 Email from New Jersey defense 0.20 89.00 counsel with a copy of the filed Notice Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 44 of 79
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Date Initials Stage Description Hours Amount of Entry of the Second Stipulation in the M.F. case and review the same. 09/18/20 SEM PHASE1 Email exchange with the Mount Baker 0.30 133.50 Council regarding documents and information related to the AIS-0696 claim, review the same and forward to BSA. 09/18/20 SEM PHASE1 Review Law 360 news story about 0.20 89.00 BSA bankruptcy court ruling in favor of BSA on limiting advertising language by plaintiff law firms and send same to BSA. 09/18/20 SEM PHASE1 Email from BSA with notice of new 0.10 44.50 lawsuit served on Silicon Valley Monterey Bay Council in California. 09/18/20 SEM PHASE1 Review newly filed and served John 0.50 222.50 GG Doe case in California involving the Silicon Valley Monterey Bay Council and related pleadings and papers. 09/18/20 SEM PHASE1 Review location of Silicon Valley 0.30 133.50 Monterey Bay Council and consider assignment of defense counsel issues. 09/18/20 SEM PHASE1 Detailed email to and reply from 0.30 133.50 Silicon Valley Monterey Bay Council with John GG Doe case summary and investigation information and request for council materials. 09/18/20 SEM PHASE1 Continue reviewing master BSA 0.50 222.50 claims spreadsheet for matters without BSA internal files and collect data to send local councils seeking information to support the creation of the same. 09/18/20 SEM PHASE1 Email exchange with Tim Anderson at 0.20 89.00 LFL regarding the setting of his deposition and preparation and his new Scouting duties. 09/18/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 Charles Hale case in New York and Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 45 of 79
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Date Initials Stage Description Hours Amount information received from the Twin Rivers Council. 09/18/20 SEM PHASE1 Review Weekly New Claims Report. 0.10 44.50 09/18/20 SEM PHASE1 Email exchange with Pine Burr Area 0.30 133.50 Council regarding AIS claim investigation and review records received about the same. 09/18/20 SEM PHASE1 Email to Tim Anderson from Kentucky 0.10 44.50 defense counsel regarding the need to pick a new deposition date. 09/18/20 SEM PHASE1 Email exchange with Puerto Rico 0.20 89.00 council regarding information and investigation into AIS claims. 09/18/20 SEM PHASE1 Email exchange with BSA and the 0.30 133.50 Greater New York Councils regarding E.R. (NY) claim. 09/18/20 SEM PHASE1 Email from Katahdin Area Council 0.20 89.00 with information and records related to AIS claim and review the same. 09/18/20 SEM PHASE1 Email exchange with Atlanta Area 0.30 133.50 Council regarding information and documents related to AIS claim investigation, review same and update perpetrator BSA internal chart. 09/18/20 SEM PHASE1 Email from Oregon Trail Council with 0.20 89.00 information and documents related to AIS claims and review the same. 09/18/20 KAD PHASE1 Email exchange with Anna Kutz 0.10 19.00 regarding completion of service on Westchester-Putnam Council in Robert Stillman lawsuit. 09/18/20 KAD PHASE1 Update Robert Stillman claim record 0.10 19.00 in Riskonnect to reflect completion of service on Westchester-Putnam Council. 09/18/20 KAD PHASE1 Review multiple emails between 1.40 266.00 Sean Manning and various Local Councils regarding AIS claim investigation and update Riskonnect Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 46 of 79
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Date Initials Stage Description Hours Amount with same per Anna Kutz request. 09/18/20 KAD PHASE1 Update Christopher Klink claim 0.10 19.00 record in Riskonnect to reflect completion of service on Westchester-Putnam Council. 09/18/20 KAD PHASE1 Prepare weekly new claims report. 0.40 76.00 09/18/20 KAD PHASE1 Email Sidley Austin, Alvarez Marsal, 0.10 19.00 BSA and Monica Blacker regarding weekly new abuse claims report. 09/18/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding complaint filed by Gerry Frettoloso. 09/18/20 KAD PHASE1 Review email from Anna Kutz 0.10 19.00 regarding service of process in John GG Doe matter. 09/18/20 KAD PHASE1 Update John GG Doe claim record 0.10 19.00 with litigation and service information. 09/18/20 KAD PHASE1 Analyze lawsuit filed by John Doe 20 0.20 38.00 G.K. in preparation of entering same in Riskonnect. 09/18/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by John Doe 20 G.K. 09/18/20 KAD PHASE1 Analyze lawsuit filed by John Doe 22 0.20 38.00 J.K. in preparation of entering same in Riskonnect. 09/18/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by John Doe 22 J.K. 09/18/20 KAD PHASE1 Analyze lawsuit filed by John Doe 27 0.20 38.00 S.N. in preparation of entering same in Riskonnect. 09/18/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by John Doe 27 S.N. 09/18/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding the lawsuit filed by Robert Bartoli. 09/18/20 KAD PHASE1 Analyze lawsuit filed by John Doe 28 0.20 38.00 J.N. in preparation of entering same Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 47 of 79
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Date Initials Stage Description Hours Amount in Riskonnect. 09/18/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by John Doe 28 J.N. 09/18/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding Charles Hale lawsuit. 09/21/20 BAG PHASE1 Begin review of Complaints recently 3.00 1,920.00 filed in New York and internal communications with S. Manning regarding same. 09/21/20 SEM PHASE1 Email from C.N.A. Insurance with 16 0.50 222.50 letters of tender of claim for various new lawsuits and claims from plaintiffs, the company's position on coverage and review same. 09/21/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 additional information related to 1 in 6 to add to BSA Youth Protection Timeline. 09/21/20 SEM PHASE1 Email exchange with Illowa Council 0.30 133.50 with information and rosters related to AIS claim investigation and review the same. 09/21/20 SEM PHASE1 Review 1 in 6 data and materials 0.20 89.00 received from BSA and include pertinent information for BSA Youth Protection Timeline. 09/21/20 SEM PHASE1 Research Los Angeles Times website 0.40 178.00 of BSA internal files to attempt to locate perpetrator of John GG Doe in California. 09/21/20 SEM PHASE1 Email from Tim Anderson regarding 0.10 44.50 additional time he would be available for deposition and preparation for the same. 09/21/20 SEM PHASE1 Email exchange with Laurel 0.30 133.50 Highlands Council regarding information and documents related to AIS claim investigation, review same and forward to BSA. 09/21/20 SEM PHASE1 Continue reviewing master claims 1.80 801.00 Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 48 of 79
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Date Initials Stage Description Hours Amount spreadsheet for AIS and other group claimant matters that identify an alleged perpetrator, but where no BSA internal file exists and compile data for further follow-up with local councils for information and documents to create same. 09/21/20 SEM PHASE1 Email to California defense counsel 0.20 89.00 with John GG Doe case assignment and details. 09/21/20 SEM PHASE1 Email from Puerto Rico Council with 0.30 133.50 additional information related to the AIS claim investigation process, review same, revise AIS chart and forward to BSA. 09/21/20 SEM PHASE1 Email from Minsi Trails Council with 0.30 133.50 additional information related to the AIS claim investigation process, review same, revise AIS chart and forward to BSA. 09/21/20 SEM PHASE1 Email exchange with Greater Niagara 0.30 133.50 Frontier Council regarding correspondence from CHUBB insurance related to various claims pending against the council, review same and forward to BSA. 09/21/20 SEM PHASE1 Review report on Kansas City 0.30 133.50 employment matter and provide input on what determines abuse. 09/21/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 new Scout Executive at the Mountain West Council. 09/21/20 SEM PHASE1 Telephone call with Mountain West 0.20 89.00 Council regarding AIS claim investigation. 09/21/20 SEM PHASE1 Email to Mountain West Council in 0.10 44.50 follow-up to AIS investigation request and to memorialize telephone call regarding the same. 09/21/20 SEM PHASE1 Email exchange with Greater New 0.20 89.00 York Councils regarding service of Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 49 of 79
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Date Initials Stage Description Hours Amount process in the Russell Kaufman case. 09/21/20 SEM PHASE1 Email to BSA and BSA Team with 0.10 44.50 notice received from Greater New York Councils related to service of process in the Russell Kaufman case. 09/21/20 SEM PHASE1 Email to New York defense counsel 0.10 44.50 with documents received from Greater New York Councils related to service of process in the Russell Kaufman case. 09/21/20 SEM PHASE1 Email exchange with Kentucky 0.20 89.00 defense counsel and LFL regarding continued logistical issues in setting the deposition of Tim Anderson. 09/21/20 SEM PHASE1 Review potential for BSA abuse stay 0.20 89.00 of litigation to apply to Kansas City Jane Doe lawsuit. 09/21/20 SEM PHASE1 Multiple emails from the Michigan 0.30 133.50 Crossroads Council regarding numerous AIS claims and information and documents related to the same and review all. 09/21/20 SEM PHASE1 Email from Golden Gate Area Council 0.10 44.50 regarding AIS claim investigation. 09/21/20 SEM PHASE1 Email exchange with Istrouma Area 0.30 133.50 Council regarding information and rosters related to AIS claim, review same, update AIS claim chart and forward to BSA with further information. 09/21/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 Thomas Ellison case in New York and information we have regarding the same. 09/21/20 SEM PHASE1 Email exchange with Istrouma Area 0.20 89.00 Council regarding request for additional information related to all claims pending against the council. 09/21/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 details of Pack 31 information as it Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 50 of 79
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Date Initials Stage Description Hours Amount pertains to AIS claim investigation. 09/21/20 SEM PHASE1 Review Istrouma Area Council Claims 0.10 44.50 Report sent by BSA to council. 09/21/20 SEM PHASE1 Email exchange with Arkansas 0.30 133.50 defense counsel regarding revisions to the notice of stay to be filed and background on Schedules to same and service on the Westark Council. 09/21/20 SEM PHASE1 Email exchange with Arkansas 0.20 89.00 defense counsel regarding filing of the Notice of Stay in the Colwell case. 09/21/20 KAD PHASE1 Review news article regarding more 0.10 19.00 abuse claims against BSA. 09/21/20 KAD PHASE1 Analyze lawsuit filed by John Doe 29 0.20 38.00 C.P. in preparation of entering same in Riskonnect. 09/21/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by John Doe 29 C.P. 09/21/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding Michael O'Neill lawsuit. 09/21/20 KAD PHASE1 Analyze lawsuit filed by John Doe 32 0.20 38.00 H.T. in preparation of entering same in Riskonnect. 09/21/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by John Doe 32 H.T. 09/21/20 KAD PHASE1 Analyze lawsuit filed by John Doe 33 0.20 38.00 J.V. in preparation of entering same in Riskonnect. 09/21/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by John Doe 33 J.V. 09/21/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding Thomas Ellison lawsuit. 09/21/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding Darrel Forde lawsuit. 09/21/20 KAD PHASE1 Analyze lawsuit filed by John Doe 0.20 38.00 N.C. in preparation of entering same in Riskonnect. Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 51 of 79
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Date Initials Stage Description Hours Amount 09/21/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by John Doe N.C. 09/21/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding John Doe 27 S.N. 09/21/20 KAD PHASE1 Update John GG Doe claim record in 0.10 19.00 Riskonnect to reflect assignment of defense counsel. 09/21/20 KAD PHASE1 Manipulate and merge claim 2.00 380.00 valuation data from attorney into master claims tracking spreadsheet. 09/21/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding Anonymous 1 and Anonymous 2 lawsuits. 09/22/20 SEM PHASE1 Email exchange with BSA requesting 0.30 133.50 contact be made with Ventura County Council in regard to a letter of representation received from a claimant's counsel and send email to same. 09/22/20 SEM PHASE1 Email exchange with Mountain West 0.30 133.50 Council regarding information and documents related to AIS claim investigation and review the same. 09/22/20 SEM PHASE1 Review news stories regarding 0.30 133.50 Georgia couple with Scouting ties arrested for child porn and Idaho 2017 BSA lawsuit. 09/22/20 SEM PHASE1 Review additional information 0.10 44.50 received from the Illowa Council regarding AIS claim investigation and copy same to BSA. 09/22/20 SEM PHASE1 Email from Northern New Jersey 0.20 89.00 Council with additional information and documents related to the AIS - 0043 claim, review same and forward to BSA. 09/22/20 SEM PHASE1 Email from Northern New Jersey 0.20 89.00 Council with additional information and documents related to the AIS - 0999 claim and review same. Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 52 of 79
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Date Initials Stage Description Hours Amount 09/22/20 SEM PHASE1 Review letter of representation for 0.10 44.50 L.D. (IN) received by BSA related to abuse in the LaSalle Council in Indiana. 09/22/20 SEM PHASE1 Email to LaSalle Council regarding 0.40 178.00 L.D. (IN) claim and action regarding the same. 09/22/20 SEM PHASE1 Email exchange between Tin 0.20 89.00 Anderson and Kentucky defense counsel regarding Plaintiffs' counsel request to change date of his deposition. 09/22/20 SEM PHASE1 Voice mail left for Ventura County 0.10 44.50 Council regarding letter received from claimant's attorney and need to discuss the same. 09/22/20 SEM PHASE1 Email discussion with BSA regarding 0.20 89.00 Duffy case in New York. 09/22/20 SEM PHASE1 Email exchange with Greater New 0.30 133.50 York Councils regarding service of process in the PC-45 Doe case and review the same. 09/22/20 SEM PHASE1 Email to New York defense counsel 0.10 44.50 with information regarding service of process in the PC-45 Doe case. 09/22/20 SEM PHASE1 Review inquiry from Plaintiff to OMNI 0.20 89.00 and provide information related to John Doe (950302) case. 09/22/20 SEM PHASE1 Continue to review master claims 1.20 534.00 spreadsheet of claims and collect data related to claims with identified perpetrators, but no BSA internal files for further follow-up with the local councils. 09/22/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 claimant's counsel seeking information from the Bay Area Council in Galveston, Texas. 09/22/20 SEM PHASE1 Review voice mail from claimant's 0.20 89.00 counsel regarding request for information from the Bay Area Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 53 of 79
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Date Initials Stage Description Hours Amount Council and telephone call to Scout Executive regarding the same. 09/22/20 SEM PHASE1 Telephone call to claimant's counsel 0.20 89.00 regarding claims related to Bay Area Council and discuss BSA bankruptcy. 09/22/20 SEM PHASE1 Email to claimant's counsel with BSA 0.10 44.50 bankruptcy proof of claim form and related notice related to Bay Area Council. 09/22/20 SEM PHASE1 Email to BSA to advise of discussions 0.10 44.50 and activity related to Bay Area Council claimant and handling of the same. 09/22/20 SEM PHASE1 Email from LaSalle Council with 0.10 44.50 information related to the L.D. (IN) claim. 09/22/20 SEM PHASE1 Email from Sidley in response to 0.20 89.00 Arkansas defense counsel billing inquiry and forward said response to Arkansas defense counsel. 09/22/20 SEM PHASE1 Email from Baden-Powell Council 0.10 44.50 with notice of service of process in the Porchenick case. 09/22/20 SEM PHASE1 Email to local New York defense 0.20 89.00 counsel to advise of service of process on the Baden-Powell Council in the Porchenick case. 09/22/20 SEM PHASE1 Email to Suffolk County Council to 0.10 44.50 advise of service of process on the Baden-Powell Council in the Michael Porchenick case as a heads up for them to be served. 09/22/20 SEM PHASE1 Email from Greater New York 0.20 89.00 Councils with voice mail left by Keith Gamble regarding a response to his claim. 09/22/20 SEM PHASE1 Review voice mail message from 0.20 89.00 Keith Gamble in New York and research claim to determine if he is represented by counsel or for possible return call and email BSA Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 54 of 79
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Date Initials Stage Description Hours Amount regarding approval for the same. 09/22/20 SEM PHASE1 Additional email exchange with 0.20 89.00 Greater New York Councils regarding the handling of the phone call from Lawrence Gamble. 09/22/20 SEM PHASE1 Email exchange with New Jersey 0.30 133.50 defense counsel regarding Plaintiff Paul Court's request to the court to withdraw the prior dismissal of BSA based on the bankruptcy stay and review the same. 09/22/20 SEM PHASE1 Telephone call to Lawrence Gamble 0.30 133.50 regarding his BSA abuse claim and advise BSA and Greater New York Councils of the same. 09/22/20 SEM PHASE1 Email exchange with Narragansett 0.30 133.50 Council in Rhode Island regarding documents and information in response to requests about several AIS claims there and review the same. 09/22/20 SEM PHASE1 Revise AIS claim spreadsheet with 0.40 178.00 information received from the Narragansett Council related to the same. 09/22/20 SEM PHASE1 Email from New Mexico defense 0.10 44.50 counsel with Defendant Richard Lucero’s Response to Plaintiff’s Motion to Compel Compliance with the Court’s Order of August 27, 2020 in the John Doe (NM) case and review the same. 09/22/20 SEM PHASE1 Email from Michigan Crossroads 0.20 89.00 Council with information related to AIS - 0358, review same and forward to BSA. 09/22/20 SEM PHASE1 Email from Atlanta Area Council with 0.20 89.00 information and documents related to AIS-0018, review same and update the master claims spreadsheet. 09/22/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 55 of 79
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Date Initials Stage Description Hours Amount regarding Anonymous 1 and Anonymous 2 lawsuits. 09/22/20 KAD PHASE1 Review email from Anna Kutz 0.10 19.00 regarding new L.D. (IN) pre-litigation same and entering same in Riskonnect. 09/22/20 KAD PHASE1 Analyze lawsuit filed by JA-017 Doe 0.20 38.00 in preparation of entering same in Riskonnect. 09/22/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by JA-017 Doe. 09/22/20 KAD PHASE1 Analyze lawsuit filed by John Doe 26 0.20 38.00 K.M. in preparation of entering same in Riskonnect. 09/22/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by John Doe 26 K.M. 09/22/20 KAD PHASE1 Analyze lawsuit filed by John Doe 39 0.20 38.00 A.A. in preparation of entering same in Riskonnect. 09/22/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by John Doe 39 A.A. 09/22/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding Daniel Duffey lawsuit. 09/22/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by John Doe 41 R.A. 09/22/20 KAD PHASE1 Analyze lawsuit filed by John Doe 41 0.20 38.00 R.A. in preparation of entering same in Riskonnect. 09/22/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by John Doe 44 C.G. 09/22/20 KAD PHASE1 Analyze lawsuit filed by John Doe 44 0.20 38.00 C.G. in preparation of entering same in Riskonnect. 09/22/20 KAD PHASE1 Review email from Lynn Sammon 0.10 19.00 regarding service of process on Greater New York Councils in PC-45- Doe case. 09/22/20 KAD PHASE1 Review email from Blair Warner 0.20 38.00 Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 56 of 79
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Date Initials Stage Description Hours Amount regarding New York case inquiry through OMNI and correspond with Sean Manning and Bruce Griggs regarding same. 09/22/20 KAD PHASE1 Email exchange with Kathleen 0.10 19.00 Russell regarding defendant's response to plaintiff's motion to compel in the John Doe v. Lucero (NM) case. 09/22/20 KAD PHASE1 Review defendant's response to 0.10 19.00 plaintiff's motion to compel in connection with the John Doe v. Lucero (NM) lawsuit. 09/22/20 KAD PHASE1 Email exchange with Anna Kutz 0.10 19.00 regarding Michael Allen-Porchenick lawsuit. 09/22/20 KAD PHASE1 Review email from Lynn Sammon 0.10 19.00 regarding voice mail received from potential claimant and listen to actual voice mail from potential claimant. 09/22/20 KAD PHASE1 Email exchange with Anna Kutz and 0.10 19.00 Sean Manning regarding voice mail from potential claimant in NY. 09/22/20 KAD PHASE1 Update Michael Allen-Porchenick 0.10 19.00 claim record in Riskonnect to reflect completion of process of service on Baden-Powell Council. 09/22/20 KAD PHASE1 Internal team conference call to 0.20 38.00 discuss overall status of the bankruptcy case and all claims. 09/23/20 SEM PHASE1 Email exchange with Longhouse 0.20 89.00 Council in New York regarding service of process in the Daniel O'Grady case. 09/23/20 SEM PHASE1 Email exchange with Longhouse 0.20 89.00 Council in New York regarding receipt of denial of coverage in the previously unknown Edward Servatius case by the insurance carrier for the co- defendant church. 09/23/20 SEM PHASE1 Email exchange with Longhouse 0.20 89.00 Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 57 of 79
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Date Initials Stage Description Hours Amount Council in New York regarding receipt of denial of coverage for Marsh Law Firm claims from CHUBB insurance - the BSA insurance carrier. 09/23/20 SEM PHASE1 Review correspondence from the Rip 0.20 89.00 Van Wrinkle Council related to CHUBB denial of coverage for BSA abuse claims brought against the council and review the same. 09/23/20 SEM PHASE1 Email from Kentucky defense counsel 0.60 267.00 regarding plaintiff’s recent responses to Louisville Metro’s second set of discovery requests and review the same. 09/23/20 SEM PHASE1 Review report from Kentucky defense 0.10 44.50 counsel regarding the Discovery Status Conference held in the LFL cases and not dates to docket from the same. 09/23/20 SEM PHASE1 Email exchange with New Mexico 0.20 89.00 defense counsel regarding the Notice of Status Conference received from the Court in the John Doe v. Richard Lucero matter and review the same. 09/23/20 SEM PHASE1 Email exchange with New Jersey 0.70 311.50 defense counsel regarding co- defendant VFW's Motion for Dismissal and review of all related pleadings about the same. 09/23/20 SEM PHASE1 Email to BSA, BSA Team and New 0.20 89.00 York defense counsel regarding service of process on the Longhouse Council in the Daniel O'Grady case. 09/23/20 SEM PHASE1 Review Edward Servatius' 32 page 0.40 178.00 lawsuit filed against the Longhouse Council in New York. 09/23/20 SEM PHASE1 Revise and update the New York 0.20 89.00 litigation tracking chart to include pertinent details from the Edward Servatius lawsuit against BSA and the Lnghouse Council. Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 58 of 79
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Date Initials Stage Description Hours Amount 09/23/20 SEM PHASE1 Review BSA internal file for Robert 0.20 89.00 Prior, the alleged perpetrator in the Edward Servatius case in New York. 09/23/20 SEM PHASE1 Revise New York litigation tracking 0.10 44.50 chart to include additional information related to the Edward Servatious lawsuit from Robert Prior's BSA internal file. 09/23/20 SEM PHASE1 Email to Longhouse Council, Anna 0.20 89.00 Kutz at BSA, Kelci Davis and Katie Murray at Ogletree regarding review of Edward Servatius lawsuit details and request for information related to the same. 09/23/20 SEM PHASE1 Email to Melik and Porter law firm in 0.20 89.00 New York to assign the new Edward Servatius lawsuit and advise to file the usual BSA responsive pleadings. 09/23/20 SEM PHASE1 Email discussion with Heidi Steppe 0.30 133.50 and Anna Kutz at BSA and Kelci Davis at Ogletree regarding information and documents related to Redacted claim in Pennsylvania that BSA received from Scouts Canada and the alleged perpetrator Turley. 09/23/20 SEM PHASE1 Review child sexual abuse CLE 0.40 178.00 materials received form New York defense counsel that include a section on BSA abuse litigation from the Plaintiff's perspective. 09/23/20 SEM PHASE1 Email exchange with New York 0.20 89.00 defense counsel regarding plaintiff perspective CLE attended that included a section about BSA abuse litigation. 09/23/20 SEM PHASE1 Email to BSA with plaintiff's CLE 0.20 89.00 materials related to BSA abuse litigation and discussion of the same. 09/23/20 SEM PHASE1 Email from Longhouse Council with 0.20 89.00 documents and information related to Edward Servatius lawsuit, review the Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 59 of 79
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Date Initials Stage Description Hours Amount same and respond to council. 09/23/20 SEM PHASE1 Email from Northern Star Council with 0.20 89.00 documents and information related to AIS claims, review the same and respond to council. 09/23/20 SEM PHASE1 Email from Narragansett Council with 0.10 44.50 additional information related to AIS- 0952 claim and review the same. 09/23/20 SEM PHASE1 Review documents served on the 0.30 133.50 Greater New York Councils in six lawsuits pending against the council and prepare to send notice of the same to BSA and defense counsel. 09/23/20 SEM PHASE1 Email to New York defense counsel 0.20 89.00 and BSA with information related to six lawsuits served on Greater New York Councils. 09/23/20 SEM PHASE1 Review new lawsuit filed for Frank 0.30 133.50 Hunt in New York against the Longhouse Council and collect details of the same for the New York litigation tracking chart. 09/23/20 SEM PHASE1 Telephone call with Ventura County 0.10 44.50 Council regarding letter of representation received and forwarding same for review and follow-up. 09/23/20 SEM PHASE1 Review new lawsuit filed for John 0.20 89.00 Doe 810324 in New York against the Greater Niagara Frontier Council and collect details of the same for the New York litigation tracking chart. 09/23/20 SEM PHASE1 Email to Greater New York Councils 0.10 44.50 to advise of receipt of service of process documents and forwarding to local defense counsel. 09/23/20 SEM PHASE1 Email requesting BSA internal files 0.10 44.50 identified in newly filed New York lawsuits. 09/23/20 SEM PHASE1 Email to Longhouse Council to advise 0.20 89.00 of new lawsuit filed for Frank Hunt Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 60 of 79
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Date Initials Stage Description Hours Amount with details of the case and request for information related to the same. 09/23/20 SEM PHASE1 Email to Greater Niagara Frontier 0.20 89.00 Council to advise of new lawsuit filed for John Doe with details of the case and request for information related to the same. 09/23/20 KAD PHASE1 Analyze lawsuit filed by JA-001 Doe 0.20 38.00 in preparation of entering same in Riskonnect. 09/23/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by JA-001 Doe. 09/23/20 KAD PHASE1 Analyze lawsuit filed by JA-005 Doe 0.20 38.00 in preparation of entering same in Riskonnect. 09/23/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by JA-005 Doe. 09/23/20 KAD PHASE1 Email exchange with Kathleen 0.10 19.00 Russell regarding notice of status conference in John Doe (NM) case. 09/23/20 KAD PHASE1 Review notice of status conference 0.10 19.00 filed by the court in the John Doe (NM) case. 09/23/20 KAD PHASE1 Analyze lawsuit filed by JA-007 Doe 0.20 38.00 in preparation of entering same in Riskonnect. 09/23/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by JA-007 Doe. 09/23/20 KAD PHASE1 Analyze lawsuit filed by JA-008 Doe 0.20 38.00 in preparation of entering same in Riskonnect. 09/23/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by JA-008 Doe. 09/23/20 KAD PHASE1 Search BSA's internal files for alleged 0.20 38.00 perpetrator named in Edward Servatius lawsuit. 09/23/20 KAD PHASE1 Email exchange with Heidi Steppe 0.10 19.00 and Anna Kutz regarding Scouts Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 61 of 79
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Date Initials Stage Description Hours Amount Canada claim (T.M.). 09/23/20 KAD PHASE1 Analyze lawsuit filed by JA-009 Doe 0.20 38.00 in preparation of entering same in Riskonnect. 09/23/20 KAD PHASE1 Create new claim in Riskonnect for 1.00 190.00 lawsuit filed by JA-009 Doe. 09/23/20 KAD PHASE1 Review email from Brittany Carlson 0.10 19.00 regarding discovery status conference and record deadlines regarding same. 09/23/20 KAD PHASE1 Review rosters and email from Helen 0.20 38.00 Forward regarding Edward Servatius lawsuit. 09/23/20 KAD PHASE1 Review email and rosters from John 0.20 38.00 Andrews regarding AIS claim investigation. 09/24/20 SEM PHASE1 Review BSA internal file for Edmond 0.30 133.50 Schroer, alleged perpetrator in the new John Doe case filed in New York against the Greater Niagara Frontier Council. 09/24/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 information obtained from the Edmund Schroer BSA internal relative tot he T.C. and John Doe lawsuits against the Greater Niagara Frontier Council. 09/24/20 SEM PHASE1 Review BSA internal file for Jim 0.40 178.00 Froehlig related to AIS-0411 claim against the Northern Star Council and update AIS claims chart to include data from the same. 09/24/20 SEM PHASE1 Email exchange with Sidley regarding 0.20 89.00 John Doe (950302) case and request from need to return a call to co- defendant and alleged perpetrator Garth Hahn. 09/24/20 SEM PHASE1 Telephone call from Garth Hahn, co- 0.20 89.00 defendant and alleged perpetrator in the John Doe (950302) case in New Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 62 of 79
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Date Initials Stage Description Hours Amount York against the Twin Rivers Council. 09/24/20 SEM PHASE1 Email exchange with the Last Frontier 0.30 133.50 Council in Oklahoma with information related to AIS claims, update the AIS claims tracking spreadsheet and forward same to BSA. 09/24/20 SEM PHASE1 Email from AIG Insurance with 0.20 89.00 correspondence regarding reservation of rights on about 135 BSA abuse claims from across the country and review the same. 09/24/20 SEM PHASE1 Email exchange with Allegheny 0.20 89.00 Highlands Council with complaint served in the Ross Anderson lawsuit and request for records related to the same. 09/24/20 SEM PHASE1 Review newly filed and served lawsuit 0.30 133.50 against the Allegheny Highlands Council in New York for Ross Anderson and compile data from the same for the New York litigation tracking chart. 09/24/20 SEM PHASE1 Email to New York defense counsel 0.10 44.50 to advise of service of process on the Allegheny Highlands Council in the Ross Anderson case. 09/24/20 SEM PHASE1 Telephone call from Ventura County 0.10 44.50 Council regarding A.A. (CA) letter of representation. 09/24/20 SEM PHASE1 Review A.A. (CA) letter of 0.20 89.00 representation involving the Ventura County Council and prior notice of the same and email council with follow-up request for information. 09/24/20 SEM PHASE1 Email exchange with New York 0.20 89.00 defense counsel regarding the Notice of Entry of Second Agreed Stipulation drafted to file in the City of Rye third- party contribution case. 09/24/20 SEM PHASE1 Review draft Notice of Second 0.20 89.00 Stipulation and Agreed Order Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 63 of 79
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Date Initials Stage Description Hours Amount prepared by New York defense counsel for filing in the City of Rye third-party contribution case for input on the same. 09/24/20 SEM PHASE1 Email from Suffolk County Council 0.10 44.50 with service of process documents in the Michael Porchenick-Allen case and review the same. 09/24/20 SEM PHASE1 Email to New York defense counsel 0.10 44.50 and BSA with service of process documents received from the Suffolk County Council in the Porchenick case. 09/24/20 SEM PHASE1 Email exchange with Greater Niagara 0.20 89.00 Frontier Council regarding new John Doe case and connection with prior T.C. lawsuit. 09/24/20 SEM PHASE1 Email exchange with California 0.20 89.00 defense counsel regarding the filing of the Notice of Second Consent Order in the John GG Doe lawsuit and contact with Plaintiff's counsel about the same. 09/24/20 SEM PHASE1 Email from BSA with service of 0.10 44.50 process documents in the John Devanney case received by the Westchester-Putnam Council in New York and review the same. 09/24/20 SEM PHASE1 Email to Westchester-Putnam 0.10 44.50 Council to advise of receipt of service of process documents in the John Devanney case. 09/24/20 SEM PHASE1 Email to New York defense counsel 0.10 44.50 with notice of service of process in the John DeVanney case against the Westchester-Putnam Council. 09/24/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 service of process in the PC-6 Doe case against BSA and the Seneca Waterways Council. 09/24/20 SEM PHASE1 Email to New York defense counsel 0.20 89.00 Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 64 of 79
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Date Initials Stage Description Hours Amount with service of process documents received by the Seneca Waterways Council in the PC-6 Doe case. 09/24/20 SEM PHASE1 Email from BSA with service of 0.10 44.50 process documents served on the national council in John Doe v. Greater Niagara Frontier Council in New York. 09/24/20 SEM PHASE1 Email to New York defense counsel 0.20 89.00 with service of process documents received by BSA National in the John Doe v. Greater Niagara Frontier Council case and related service of process information. 09/24/20 SEM PHASE1 Email exchange with Seneca 0.20 89.00 Waterways Council and BSA regarding Francis K. Feeney lawsuit and information known about the same. 09/25/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 improper service of process on the National BSA Council in the City of Rye case and review same. 09/25/20 SEM PHASE1 Email to New York defense counsel 0.20 89.00 regarding the City of Rye's improper service of process on BSA National and the response to the same. 09/25/20 SEM PHASE1 Further discussions with Kentucky 0.30 133.50 defense counsel and LFL regarding Plaintiff's desire to once again re-set Tim Anderson's deposition. 09/25/20 SEM PHASE1 Review Weekly New Claims Report 0.20 89.00 and send information related to the new Frank Hunt case to New York defense counsel. 09/25/20 SEM PHASE1 Email exchange with Westark Council 0.20 89.00 regarding new council attorney and research into applicable Arkansas statutes of limitation. 09/25/20 SEM PHASE1 Review news story from New York 0.30 133.50 regarding Scout leader arrested for Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 65 of 79
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Date Initials Stage Description Hours Amount sexual abuse of Scouts and forward same to BSA. 09/25/20 SEM PHASE1 Email exchange with BSA and 0.30 133.50 Kiwanis Club General Counsel regarding service of process on Kiwanis as the chartered organization in the Francis Feeney case in New York involving the Seneca Waterways Council and discussion of further involvement of Kiwanis. 09/25/20 SEM PHASE1 Review rosters and complaint 0.20 89.00 information from the Francis Feeney case in New York. 09/25/20 SEM PHASE1 Email to Seneca Waterways Council 0.10 44.50 to advise of Kiwanis Club service of process in the Francis Feeney case and to be alert to service on the Council. 09/25/20 SEM PHASE1 Email exchange with New York 0.20 89.00 defense counsel regarding the Court's order for status conference in the John Doe 905302 case and appearance at same. 09/25/20 SEM PHASE1 Email from Northwest Texas Council 0.20 89.00 with information and documents related to in response to AIS claim investigation and review the same. 09/25/20 SEM PHASE1 Email exchange with California 0.30 133.50 defense counsel regarding information obtained from Plaintiff's counsel in the John GG Doe case, update California Litigation Tracking Chart with same and forward said information to BSA. 09/25/20 SEM PHASE1 Review publicly available IV File for 0.10 44.50 alleged perpetrator in the John GG Doe case received from California defense counsel. 09/25/20 SEM PHASE1 Email from Georgia defense counsel 0.80 356.00 with Plaintiff's 56 page Response to Defendant Bobo's Motion to Dismiss in the Robert Lawson case and Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 66 of 79
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Date Initials Stage Description Hours Amount review the same. 09/25/20 KAD PHASE1 Update Bartoli, Telemaco and 0.20 38.00 Fuentes claim records to reflect completion of service of process on Greater New York Council and Bronx Council. 09/25/20 KAD PHASE1 Search BSA's internal files for alleged 0.30 57.00 perpetrators named in Hunt and John Doe (810324) lawsuits. 09/25/20 KAD PHASE1 Run keyword search in BSA's internal 0.30 57.00 files for "Camp Drake" per Heidi Steppe's request. 09/25/20 KAD PHASE1 Email exchange with Heidi Steppe 0.10 19.00 regarding key word search. 09/25/20 KAD PHASE1 Analyze BSA internal files from Camp 1.20 228.00 Drake key word search results. 09/25/20 KAD PHASE1 Prepare report summarizing files from 0.20 38.00 Camp Drake key word search. 09/25/20 KAD PHASE1 Email exchange with Nicole 0.10 19.00 Liberatore regarding notice of second stipulation and agreed order filed in Edward Servatius lawsuit. 09/25/20 KAD PHASE1 Analyze rosters from Francis Feeney 0.20 38.00 lawsuit in preparation of responding to question regarding same from Anna Kutz. 09/25/20 KAD PHASE1 Communicate with Anna Kutz via 0.10 19.00 chatter regarding alleged chartered organization from Francis Feeney lawsuit. 09/25/20 KAD PHASE1 Review service of process on 0.10 19.00 National Council in John Doe (810324/2020) lawsuit and email from Anna Kutz regarding same. 09/25/20 KAD PHASE1 Email exchange with Anna Kutz 0.10 19.00 regarding completion of service on Westchester-Putnam Council and update John Devanney claim record with same. Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 67 of 79
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Date Initials Stage Description Hours Amount 09/25/20 KAD PHASE1 Email exchange with Anna Kutz 0.10 19.00 regarding completion of service on Seneca Waterways Council and update PC-6 Doe claim record with same. 09/25/20 KAD PHASE1 Conference call with Anna Kutz 0.30 57.00 regarding remaining claims to enter in RK and email exchange regarding same. 09/25/20 KAD PHASE1 Email Sidley Austin, Alvarez Marsal, 0.10 19.00 BSA and Monica Blacker regarding weekly new abuse claims report. 09/25/20 KAD PHASE1 Prepare weekly new claims report. 1.00 190.00 09/28/20 SEM PHASE1 Review multiple emails from the 0.50 222.50 Greater New York Councils with information and records related to multiple newly filed lawsuits and update the New York litigation tracking chart accordingly. 09/28/20 SEM PHASE1 Email to BSA with extensive 0.20 89.00 collection of information from the Greater New York Councils related to recently filed lawsuits against the Council. 09/28/20 SEM PHASE1 Review BSA internal file for alleged 0.30 133.50 perpetrator in the Ross Anderson case filed in New York. 09/28/20 SEM PHASE1 Review BSA internal file for alleged 0.20 89.00 perpetrator in John GG Doe case in California. 09/28/20 SEM PHASE1 Email exchange with Northeast 0.20 89.00 Georgia Council regarding the need for a complete lit of all pending claims and litigation against their council. 09/28/20 SEM PHASE1 Review 15 emails from AXIS 0.40 178.00 Insurance to Plaintiff's counsels regarding numerous BSA abuse claims and the company's denial of coverage for the same. 09/28/20 SEM PHASE1 Email from BSA to Northeast Georgia 0.20 89.00 Council with spreadsheet of all claims Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 68 of 79
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Date Initials Stage Description Hours Amount and lawsuits and review the same. 09/28/20 SEM PHASE1 Email exchange with BSA regarding 0.50 222.50 additional new information to add to the BSA Youth Protection timeline and update the same. 09/28/20 SEM PHASE1 Email exchange between BSA and 0.20 89.00 Northeast Georgia Council regarding an AIS claim improperly associated with their council. 09/28/20 SEM PHASE1 Email exchange with BSA regarding 0.30 133.50 AIS - 0195 and research information related to the same. 09/28/20 SEM PHASE1 Email from Potawatomi Area Council 0.20 89.00 with information related to AIS - 0673 and review same. 09/28/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 handling of John GG Doe case in California. 09/28/20 SEM PHASE1 Email from Kentucky defense counsel 0.20 89.00 with summary of newly entered docket deadlines during Discovery Status Conference in the LFL cases and review order related to the same. 09/28/20 SEM PHASE1 Email from BSA regarding Missoula 0.10 44.50 Council Troop 60 adult rosters for AIS investigation. 09/28/20 SEM PHASE1 Email notice of new Darrin Purcell 0.40 178.00 lawsuit filed in New York against the Greater New York Councils, review the same and add details to the New York litigation tracking chart. 09/28/20 SEM PHASE1 Email from Greater New York 0.20 89.00 Councils with information related to recently filed lawsuits against the council, review the same and revise the New York litigation tracking chart. 09/28/20 SEM PHASE1 Review notices of three (3) additional 0.30 133.50 new BSA abuse lawsuits filed in New York and coordinate collection of Complaints from the same. Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 69 of 79
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Date Initials Stage Description Hours Amount 09/28/20 SEM PHASE1 Email exchange with New York 0.20 89.00 defense counsel regarding Jay Martin v. Boston Minuteman Council lawsuit and Plaintiff's attempt to obtain relief from the prior Summary Judgment Order. 09/28/20 KAD PHASE1 Review email from Michael Todisco 0.10 19.00 regarding the identities of the claimant and perpetrator and update John GG Doe's claim record with same. 09/28/20 KAD PHASE1 Communicate with BSA Legal and 0.10 19.00 Membership Standards via Chatter regarding the identities of the plaintiff and perpetrator in the John GG Doe case. 09/28/20 KAD PHASE1 Search BSA's internal files for alleged 0.20 38.00 perpetrator from John GG Doe lawsuit and review file for same. 09/28/20 KAD PHASE1 Search BSA's internal files for alleged 0.20 38.00 perpetrator from Ross Anderson lawsuit and review file for same. 09/28/20 KAD PHASE1 Email exchange with Nicole 0.10 19.00 Liberatore regarding John Doe (810324) lawsuit. 09/28/20 KAD PHASE1 Analyze multiple coverage letters 0.50 95.00 from Axis regarding various New York lawsuits. 09/28/20 KAD PHASE1 Enter minimal information into 5.00 950.00 Riskonnect for 30 New York lawsuits per Anna Kutz request. 09/29/20 BAG PHASE1 Review email correspondence from 0.50 320.00 Massachusetts defense counsel regarding claim from Jay Martin and direct internal investigation regarding same. 09/29/20 SEM PHASE1 Email from Sidley regarding lawsuits 0.20 89.00 in New York proceeding against Chartered Organizations and need to investigate same and review of email string with TCC regarding the same. Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 70 of 79
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Date Initials Stage Description Hours Amount 09/29/20 SEM PHASE1 Research cases in New York 0.50 222.50 allegedly proceeding against Chartered Organizations brought to our attention by the TCC and provide information to Sidley related to the same. 09/29/20 SEM PHASE1 Review letter to New York defense 0.50 222.50 counsel, letter to Court, Notice and Motion for Relief from Judgment related to the Jay Martin v. Boston Minuteman Council case and provide input on the same. 09/29/20 SEM PHASE1 Review new lawsuit filed in New York 0.30 133.50 for Joe Soluri against the Longhouse Council and add details of the same to the New York litigation tracking chart. 09/29/20 SEM PHASE1 Review new lawsuit filed in New York 0.70 311.50 for Michael Wickham against the Westchester-Putnam Council and add details of the same to the New York litigation tracking chart, including research on all of the nine (9) additionally named councils. 09/29/20 SEM PHASE1 Email exchange with Suffolk County 0.20 89.00 Council regarding notice from CHUBB denying coverage for claims against the council. 09/29/20 SEM PHASE1 Send request for BSA internal files for 0.10 44.50 all newly identified alleged perpetrators in New York lawsuits for review. 09/29/20 SEM PHASE1 Email to Greater New York Council 0.10 44.50 and BSA with notice of new lawsuit for Darrin Purcell. 09/29/20 SEM PHASE1 Email to Longhouse Council and BSA 0.20 89.00 with notice of new lawsuit filed for Joe Soluri with information related to the same and request for information. 09/29/20 SEM PHASE1 Email to Westchester-Putnam 0.20 89.00 Council and BSA with notice of new lawsuit filed by Michael Wickham, Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 71 of 79
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Date Initials Stage Description Hours Amount information related to the same and request for information. 09/29/20 SEM PHASE1 Email from, Westchester-Putnam 0.10 44.50 Council to advise they have no information related to the Michael Wickham case. 09/29/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 the Jay Martin v. Boston Minuteman Council Motion for Relief from Judgement matter. 09/29/20 SEM PHASE1 Emails to New York defense firms 0.20 89.00 with newly filed lawsuits there and assign to defend the same. 09/29/20 SEM PHASE1 Review email stating that there are no 0.10 44.50 BSA internal files for the newly identified New York perpetrators. 09/29/20 SEM PHASE1 Email from Greater New York 0.30 133.50 Councils with additional new information related to recently filed lawsuits against the council, update the litigation tracking chart and forward same to BSA. 09/29/20 SEM PHASE1 Review New York defense counsel 0.20 89.00 assignments for various recently filed lawsuits. 09/29/20 SEM PHASE1 Email exchange with New York 0.20 89.00 defense counsel regarding the status conference held in the John Doe 905302-20 case and the Court's order for subsequent hearing on November 17, 2020. 09/29/20 SEM PHASE1 Email exchange with the Katahdin 0.20 89.00 Area Council regarding the Singhel lawsuit and Council defense of the same. 09/29/20 SEM PHASE1 Additional email with the Katahdin 0.20 89.00 Area Council regarding their desire to file a Motion to Dismiss as an improper party since the abuse did not take place at their camp. 09/29/20 SEM PHASE1 Additional email with the Katahdin 0.20 89.00 Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 72 of 79
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Date Initials Stage Description Hours Amount Area Council regarding preservation of rights for potential future litigation of claims. 09/29/20 SEM PHASE1 Email exchange with Greater New 0.30 133.50 York Councils regarding CHUBB Insurance coverage denial letter and action to take on the same and review said coverage letter. 09/29/20 SEM PHASE1 Email from the Greater New York 0.10 44.50 Councils advising they cannot find any service of process in the Wilberto Melendez case. 09/29/20 KAD PHASE1 Email exchange with William Curtain 0.10 19.00 regarding New York actions not listed on Schedule 1. 09/29/20 KAD PHASE1 Investigate and compile information 0.50 95.00 regarding six New York actions not listed on Schedule 1 in preparation of responding to William Curtain regarding same. 09/29/20 KAD PHASE1 Email exchange with Nicole 0.10 19.00 Liberatore regarding notice of second stipulation and agreed order filed Ross Anderson lawsuit. 09/29/20 KAD PHASE1 Investigate and confirm the date of 0.30 57.00 loss in the Powers lawsuit in preparation of responding to Robyn Jungers regarding same. 09/29/20 KAD PHASE1 Email exchange with Robyn Jungers 0.10 19.00 regarding the date of loss in the Powers lawsuit. 09/29/20 KAD PHASE1 Analyze Complaint filed by Bleau and 0.20 38.00 R.E.M. in order to respond to question from Lynn Richardson regarding the alleged perpetrators. 09/29/20 KAD PHASE1 Email exchange with Lynn 0.10 19.00 Richardson regarding alleged perpetrators named in lawsuit filed by Bleau and R.E.M. 09/29/20 KAD PHASE1 Search BSA's internal files for alleged 0.20 38.00 perpetrators named in Joe Soluri and Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 73 of 79
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Date Initials Stage Description Hours Amount Michael Wickham cases. 09/29/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding lawsuit filed by Joseph Borbely. 09/29/20 KAD PHASE1 Enter minimal information into 5.00 950.00 Riskonnect for 31 New York lawsuits per Anna Kutz's request. 09/29/20 KAD PHASE1 Conference call with Bruce Griggs, 0.40 76.00 Sean Manning and Katie Murray to discuss overall status of claims and projects. 09/30/20 SEM PHASE1 Email from Sidley with revisions to 0.20 89.00 the Notice of Entry of Second Stipulation and Agreed Order for the City of Rye case in New York and review the same. 09/30/20 SEM PHASE1 Email to Sidley to follow-up on the 0.10 44.50 John Doe (NM) BSA internal file production matter in New Mexico. 09/30/20 SEM PHASE1 Review news article regarding a new 0.50 222.50 Plaintiff's firm beginning to handle BSA abuse cases, summarize same and send to BSA for their information. 09/30/20 SEM PHASE1 Email exchange with BSA regarding 0.20 89.00 need to follow-up on additional information for the Dan Hale case with the Longhouse Council in New York. 09/30/20 SEM PHASE1 Email to the Longhouse Council in 0.20 89.00 New York to follow-up on information related to the Dan Hale lawsuit. 09/30/20 SEM PHASE1 Email exchange with Greater New 0.20 89.00 York Councils and the attorney for the Council regarding the search for council insurance coverage in response to CHUBB denial of coverage under the BSA National policy. 09/30/20 SEM PHASE1 Review email from Greater New York 0.20 89.00 Councils in regard to the Letter of Representation for E.R. (NY) and re- Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 74 of 79
Page 73 10/20/20 Bill No. 90301668 047657.000013-BAG
Date Initials Stage Description Hours Amount review said letter. 09/30/20 SEM PHASE1 Email exchange with New York 0.20 89.00 defense counsel regarding the court ordered conference in the David Luff v. Twin Rivers case. 09/30/20 SEM PHASE1 Email exchange with New Mexico 0.20 89.00 defense counsel regarding a status conference in the John Doe v. Richard Lucero case and proposed positions on the issues. 09/30/20 SEM PHASE1 Email exchange with Greater New 0.20 89.00 York Councils regarding number of new lawsuits still needing researched. 09/30/20 SEM PHASE1 Email from Greater New York 0.30 133.50 Councils with information and documents related to recently filed lawsuits against the council, review the same and forward to BSA. 09/30/20 SEM PHASE1 Email from Greater New York Council 0.10 44.50 with information related to CJ - 00065 claim and review the same. 09/30/20 SEM PHASE1 Email from Greater New York Council 0.10 44.50 advising they were unable to locate any additional council insurance coverage. 09/30/20 SEM PHASE1 Email exchange with Northwest 0.30 133.50 Texas Council regarding information pertaining to AIS claim investigation and review information and documents received for the same. 09/30/20 KAD PHASE1 Review email from Vanessa Savoy 0.10 19.00 regarding month-end reporting and changes to Riskonnect, and forward same to Katie Murray. 09/30/20 KAD PHASE1 Email exchange with Yesmy Romero 0.10 19.00 regarding billing information and process for 112 New York lawsuits assigned to Wiggin and Dana. 09/30/20 KAD PHASE1 Enter minimal information into 0.30 57.00 Riskonnect for 3 New York lawsuits Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 75 of 79
Page 74 10/20/20 Bill No. 90301668 047657.000013-BAG
Date Initials Stage Description Hours Amount per Anna Kutz's request. 09/30/20 KAD PHASE1 Email exchange with Jennifer Nichols 0.10 19.00 regarding alleged perpetrators in KS Does case and their connection to Scouting.
Total Services: 275.00 95,112.00
Timekeeper Summary Timekeeper Title Rate Hours Amount Bruce A. Griggs Shareholder 640.00 19.10 12,224.00 Sean E. Manning Of Counsel 445.00 134.60 59,897.00 Kelci A. Davis Paralegal 190.00 119.90 22,781.00 Katie J. Murray Other 150.00 1.40 210.00 Expenses Description Amount VENDOR: Epiq eDiscovery Solutions, Inc.- AZ INVOICE#: 90472357 DATE: 9/8/2020 81.19 Professional Fees - Epiq eDiscovery Solutions, Inc.- AZ - E-discovery storage - on 09/08/20 Total Expenses 81.19
TOTAL FEES $95,112.00 TOTAL EXPENSES $81.19 TOTAL THIS BILL $95,193.19 Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 76 of 79
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 October 20, 2020 Telephone: (864) 241-1801 Facsimile: (864) 241-1908 www.ogletreedeakins.com
Elizabeth Ramirez-Washka Boy Scouts of America, The - DIP 1325 West Walnut Hill Lane P.O. Box 152079 Irving, TX 75015-2079
PERSONAL AND CONFIDENTIAL Bill # 90301657 Client.Matter # 083331.000000
Re: Boy Scouts of America, The - General Advice
For professional services rendered through September 30, 2020, in connection with the above-referenced matter as outlined on the attached detailed billing sheets:
Fees ...... $7,315.20 Expenses...... $0.00
Total Due This Bill...... $7,315.20
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 1625-2 Filed 11/03/20 Page 77 of 79
Page 2 10/20/20 Bill No. 90301657 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 September 30, 2020
Date Initials Stage Description Hours Amount 07/08/20 JLC PHASE1 Review email from and prepare email 0.20 99.00 to opposing counsel regarding Complainant receiving bankruptcy notices and questions he has received from Complainant about such notices re: Linda Evans (Black Hawk Council) case. 07/08/20 JLC PHASE1 Prepare multiple emails to and review 0.40 198.00 multiple emails from Elizabeth Washka and Anna Kutz regarding response to opposing counsel's questions about bankruptcy notices re: Linda Evans (Black Hawk Council) case. 09/01/20 GSM PHASE1 Analyze and make substantive 2.10 869.40 revisions to various letters to regional directors and employees on furlough, and correspond with Bill Davis regarding same. 09/09/20 GSM PHASE1 Analyze detailed emails regarding 0.80 331.20 complaints from local council employee in Wisconsin regarding investigation and termination decision, and correspond with Elizabeth Washka regarding same. 09/10/20 NLS PHASE1 Analyze situation involving 0.20 92.70 genderless/agender participant under current and evolving law. 09/10/20 MS PHASE1 Advise Bill Davis regarding complex 0.20 89.10 FMLA issue. 09/10/20 GSM PHASE1 Exchange emails with Elizabeth 0.10 41.40 Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 78 of 79
Page 3 10/20/20 Bill No. 90301657 083331.000000-RWC
Date Initials Stage Description Hours Amount Washka regarding local council employee in Wisconsin. 09/10/20 GSM PHASE1 Analyze issues regarding employee's 0.70 289.80 hairstyle and rap music, and exchange detailed emails with Elizabeth Washka regarding same. 09/10/20 GSM PHASE1 Analyze various issues pertaining to 0.80 331.20 transgender policy and agender/genderless scouts, and exchange emails with Elizabeth Washka regarding same. 09/14/20 GSM PHASE1 Begin analyzing extensive 1.30 538.20 communications, leave documents, emails, and chronologies sent by Cynthia Speer regarding district executive who had exhausted EFMLA but refused to return to work. 09/15/20 GSM PHASE1 Continue analyzing extensive 2.30 952.20 documentation provided by Cynthia Speer regarding emails, attendance record, leave documentation, and inquiries from local council regarding district executive who does not plan to return to work, and exchange lengthy emails with Ms. Speer regarding same. 09/15/20 GSM PHASE1 Begin analyzing issues and questions 0.60 248.40 regarding wage payments to camp staff in Puerto Rico. 09/16/20 GSM PHASE1 Continue analyzing issues pertaining 0.80 331.20 to wage paid to camp staff in Puerto Rico, and draft detailed email to Cynthia Speer regarding same. 09/16/20 GSM PHASE1 Analyze lengthy email 1.40 579.60 communications from and regarding assistant scout master in New Jersey, exchange multiple emails with Cynthia Speer and Elizabeth Washka regarding same, and analyze prior lawsuits filed by same person. 09/16/20 GSM PHASE1 Prepare for and participate in 0.60 248.40 telephone call with Cynthia Speer Case 20-10343-LSS Doc 1625-2 Filed 11/03/20 Page 79 of 79
Page 4 10/20/20 Bill No. 90301657 083331.000000-RWC
Date Initials Stage Description Hours Amount regarding employee who has exhausted EFMLA but refuses to return to work because child's daycare is closed. 09/22/20 RWC PHASE1 Multiple emails from and to Elizabeth 0.20 129.60 Washka regarding advice on situation. 09/23/20 GSM PHASE1 Draft monthly chart with status update 0.70 289.80 on all current matters. 09/28/20 GSM PHASE1 Analyze email and issues related to 0.90 372.60 confidentiality agreements in Puerto Rico, and correspond with Cynthia Speer regarding same. 09/28/20 GSM PHASE1 Analyze lengthy email and text 1.20 496.80 messages regarding complaints pertaining to religious beliefs and LGBTQ issues, and draft detailed analysis of same for Cynthia Speer and Elizabeth Washka. 09/29/20 GSM PHASE1 Analyze several detailed emails and 1.90 786.60 attachments from Cynthia Speer and Elizabeth Washka regarding race- based complaints from volunteer in New Jersey, and draft response for Ms. Washka to use.
Total Services: 17.40 7,315.20
Timekeeper Summary Timekeeper Title Rate Hours Amount Michael M. Shetterly Shareholder 445.50 0.20 89.10 Gavin S. Martinson Shareholder 414.00 16.20 6,706.80 Nonnie L. Shivers Shareholder 463.50 0.20 92.70 Jennifer L. Colvin Shareholder 495.00 0.60 297.00 Ron Chapman, Jr. Shareholder 648.00 0.20 129.60
TOTAL FEES $7,315.20 TOTAL EXPENSES $0.00 TOTAL THIS BILL $7,315.20 Case 20-10343-LSS Doc 1625-3 Filed 11/03/20 Page 1 of 7
Exhibit B
Phase 2 Fees and Expense Itemization
Case 20-10343-LSS Doc 1625-3 Filed 11/03/20 Page 2 of 7
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 October 20, 2020 Telephone: (864) 241-1801 Facsimile: (864) 241-1908 www.ogletreedeakins.com
Robyn Jungers The Boy Scouts of America Legal Department 1325 West Walnut Hill Lane P.O. Box 152079 Irving, TX 75015-2049
PERSONAL AND CONFIDENTIAL Bill # 90301669 Client.Matter # 047657.000013
Re: BSA General Defense - Bankruptcy (Billiable)
For professional services rendered through September 30, 2020, in connection with the above-referenced matter as outlined on the attached detailed billing sheets:
Fees ...... $7,121.50 Expenses...... $0.00
Total Due This Bill...... $7,121.50
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 1625-3 Filed 11/03/20 Page 3 of 7
Page 2 10/20/20 Bill No. 90301669 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 September 30, 2020
Date Initials Stage Description Hours Amount 09/01/20 BAG PHASE2 Review and respond to multiple email 0.50 320.00 exchanges with bankruptcy counsel and Kelci Davis regarding second interim fee application and attention to same. 09/01/20 KAD PHASE2 Email exchange with Eric Moats 0.20 38.00 regarding the customary comparable exhibit in support of Ogletree's Second Interim Fee Application. 09/01/20 KAD PHASE2 Calculate the blended hourly rate for 3.40 646.00 the application and comparable periods. 09/02/20 BAG PHASE2 Review email exchanges and 1.00 640.00 updated information regarding second interim fee application and finalize and send application. 09/02/20 KAD PHASE2 Revise Ogletree's Second Interim 0.50 95.00 Fee Application. 09/02/20 KAD PHASE2 Email Eric Moats regarding 0.10 19.00 Ogletree's revised 2nd Interim Fee Application. 09/03/20 KAD PHASE2 Email exchange with Nicole 0.10 19.00 Liberatore regarding billing procedures for cases recently assigned to Melick and Porter. 09/03/20 KAD PHASE2 Email exchange with Kayron Headley 0.10 19.00 regarding claims representative for Hartford. 09/04/20 KAD PHASE2 Email exchange with Nicole 0.10 19.00 Case 20-10343-LSS Doc 1625-3 Filed 11/03/20 Page 4 of 7
Page 3 10/20/20 Bill No. 90301669 047657.000013-BAG
Date Initials Stage Description Hours Amount Liberatore regarding billing process for multiple New York lawsuits recently assigned to Melick & Porter. 09/04/20 KAD PHASE2 Compile billing information and 1.10 209.00 prepare chart of same for Nicole Liberatore. 09/08/20 KAD PHASE2 Analyze and revise August's billing 4.90 931.00 entries and information for inclusion in the monthly fee application for September. 09/08/20 KAD PHASE2 Review email from Desiree Vale 0.10 19.00 regarding the CNO for Ogletree's Fifth Monthly Fee Application. 09/08/20 KAD PHASE2 Compile billing information on two 0.20 38.00 John Doe NY cases for Nicole Liberatore. 09/08/20 KAD PHASE2 Email exchange with Nicole 0.10 19.00 Liberatore regarding billing process and information on 2 John Doe NY lawsuits. 09/09/20 KAD PHASE2 Review email from Desiree Vale 0.10 19.00 regarding as-filed copies of the Certificate of No Objection regarding Ogletree's July Fee Application. 09/10/20 KAD PHASE2 Analyze Epic invoice and submit 0.10 19.00 same for processing and payment. 09/11/20 SEM PHASE2 Email exchange with BSA regarding 0.20 89.00 billing and CHUBB payments to New York defense counsel related to the J.T. case. 09/11/20 SEM PHASE2 Email exchange with Haynes and 0.20 89.00 Boone and BSA in regard to the billing issue with CHUBB in the J.T. case in New York. 09/11/20 SEM PHASE2 Additional email exchange with 0.20 89.00 Haynes and Boone regarding contact with Sidley about J.T.case billing and payment of defense counsel issue. 09/11/20 KAD PHASE2 Email exchange with Nicole 0.10 19.00 Liberatore regarding invoices for J.T. Case 20-10343-LSS Doc 1625-3 Filed 11/03/20 Page 5 of 7
Page 4 10/20/20 Bill No. 90301669 047657.000013-BAG
Date Initials Stage Description Hours Amount (NY pre-lit claim) matter and Chubb's response as to their duty to defend. 09/11/20 KAD PHASE2 Email Anna Kutz, Lynn Richardson 0.10 19.00 and Robyn Jungers regarding invoices for J.T. (NY pre-lit claim) matter and Chubb's response as to their duty to defend. 09/11/20 KAD PHASE2 Email exchange with Adrian Azer 0.10 19.00 regarding invoices for J.T. (NY pre-lit claim) matter and Chubb's response as to their duty to defend. 09/14/20 KAD PHASE2 Email exchange with Nicole 0.10 19.00 Liberatore regarding invoices for J.T. (NY pre-lit claim) matter and Chubb's response as to their duty to defend. 09/14/20 KAD PHASE2 Conduct final review of the draft 1.40 266.00 billing entries for inclusion in the monthly fee application for September. 09/16/20 KAD PHASE2 Prepare draft of Ogletree's Sixth 1.50 285.00 Monthly Fee Application. 09/16/20 KAD PHASE2 Review/analyze billing entries and 2.30 437.00 invoices for inclusion in Ogletree's Sixth Monthly Fee Application and work on required redaction for same. 09/18/20 KAD PHASE2 Review Certificate of No Objection for 0.10 19.00 Ogletree's Second Interim Fee Application and email from Glenn Reimann regarding same. 09/21/20 BAG PHASE2 Review certificate of non-objection for 0.20 128.00 second Interim fee application and exchange email with bankruptcy legal assistant at Morris Nichols regarding same. 09/21/20 BAG PHASE2 Work on 6 monthly fee application 2.00 1,280.00 and review all required data for same. 09/21/20 SEM PHASE2 Email exchange with Arkansas 0.30 133.50 defense counsel regarding billing and payment for post-bankruptcy matters, review process for the same and forward request for confirmation to Case 20-10343-LSS Doc 1625-3 Filed 11/03/20 Page 6 of 7
Page 5 10/20/20 Bill No. 90301669 047657.000013-BAG
Date Initials Stage Description Hours Amount Sidley and BSA. 09/21/20 KAD PHASE2 Review as-filed Certificate of No 0.10 19.00 Objection for Ogletree's 2nd Interim Fee Application and email from Desiree Vale regarding same. 09/22/20 KAD PHASE2 Review email from Eric Moats 0.20 38.00 regarding ledes files and submitting same to fee examiner and coordinate same with Bruce Griggs and Addie Norton. 09/23/20 KAD PHASE2 Email exchange with Justin Rucki 0.10 19.00 regarding Ogletree's fee and expense detail for all filed applications. 09/23/20 KAD PHASE2 Review lengthy email from Eric Moats 0.10 19.00 regarding fee examiner report categories and anticipated comments. 09/23/20 KAD PHASE2 Consolidate LEDES files per fee 0.40 76.00 examiner's request. 09/25/20 BAG PHASE2 Final review of 6th Monthly Fee 0.30 192.00 Application. 09/25/20 KAD PHASE2 Email exchange with Nichole 0.10 19.00 Liberatore regarding billing process and procedures for new Edward Servatius lawsuit. 09/25/20 KAD PHASE2 Email Eric Moats regarding 0.10 19.00 Ogletree's 6th Monthly Fee Application. 09/25/20 KAD PHASE2 Finalize Ogletree's 6th Monthly Fee 0.20 38.00 Application based on comments from Bruce Griggs. 09/25/20 KAD PHASE2 Telephone call with Paige Topper 0.20 38.00 regarding the redactions on the invoices submitted with Ogletree's 6th monthly fee application. 09/28/20 KAD PHASE2 Email Paige Topper regarding 0.10 19.00 redactions on invoices submitted with Ogletree's 6th monthly fee application. Case 20-10343-LSS Doc 1625-3 Filed 11/03/20 Page 7 of 7
Page 6 10/20/20 Bill No. 90301669 047657.000013-BAG
Date Initials Stage Description Hours Amount 09/28/20 KAD PHASE2 Analyze redactions on invoices 0.70 133.00 submitted with Ogletree's 6th monthly fee application based on discussion with Paige Topper. 09/28/20 KAD PHASE2 Compile billing information on 3 new, 0.10 19.00 NY lawsuits assigned to Melick & Porter. 09/28/20 KAD PHASE2 Email exchange with Nicole 0.10 19.00 Liberatore regarding billing process for 3 new, NY lawsuits assigned to Melick & Porter. 09/28/20 KAD PHASE2 Review email from Robyn Jungers 0.10 19.00 regarding billing on Arkansas abuse matters. 09/30/20 KAD PHASE2 Email exchange with Nicole 0.10 19.00 Liberatore regarding billing process for Joe Soluri lawsuit. 09/30/20 KAD PHASE2 Compile billing information on 112 2.40 456.00 New York cases newly assigned to Wiggin and Dana.
Total Services: 26.80 7,121.50
Timekeeper Summary Timekeeper Title Rate Hours Amount Bruce A. Griggs Shareholder 640.00 4.00 2,560.00 Sean E. Manning Of Counsel 445.00 0.90 400.50 Kelci A. Davis Paralegal 190.00 21.90 4,161.00
TOTAL FEES $7,121.50 TOTAL EXPENSES $0.00 TOTAL THIS BILL $7,121.50 Case 20-10343-LSS Doc 1625-4 Filed 11/03/20 Page 1 of 1
Exhibit C
Expense Summary
Category Amount Legal Support Services $81.19 TOTAL: $81.19
14282073.2