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Co-Lead Counsel Declaration ISO Motion for Fees, Costs, and… — Brooks v. Thomson Reuters Corporation (Dkt. 264.1)
Summary
The Declaration of Andre Mura and Geoffrey Graber in Support of Plaintiffs' Motion for Attorneys' Fees, Costs, and Service Awards, Document 264-1, stamped Filed 10/25/24, in Case No. 3:21-cv-1418-EMC-KAW, Cat Brooks and Rasheed Shabazz v. Thomson Reuters Corporation, Northern District of California, 17 pages, with a hearing date of February 13, 2024 before Hon. Edward M. Chen. Mura of Gibbs Law Group LLP and Graber of Cohen Milstein Sellers & Toll PLLC declare under penalty of perjury that they represent Plaintiffs in this certified class action. They recount that the complaint was filed on December 3, 2020, and that the Court granted Plaintiffs' Motion for Class Certification (ECF No. 213). They also state that by the time of settlement Thomson Reuters had produced nearly 80,000 documents, totaling nearly 500,000 pages.
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“Co-Lead Counsel Declaration ISO Motion for Fees, Costs, and… — Brooks v. Thomson Reuters Corporation (Dkt. 264.1).”
Original at ecf.cand.uscourts.gov, No. 3:21-cv-01418-EMC, Doc. 264-1. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/full-docket-brooks-thomsonreuters-cand-374304/2024-02-13-gov-uscourts-cand-374304-264-1-gov-uscourts-cand-374304-264-1/
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Case 3:21-cv-01418-EMC Document 264-1 Filed 10/25/24 Page 1 of 17
1 Andre M. Mura (SBN 298541) Geoffrey A. Graber (SBN 211547)
Ezekiel S. Wald (SBN 341490) Karina G. Puttieva (SBN 317702)
2
GIBBS LAW GROUP LLP COHEN MILSTEIN SELLERS & TOLL
3 1111 Broadway, Suite 2100 PLLC
Oakland, CA 94607 1100 New York Ave. NW, Fifth Floor
4 Washington, DC 20005
Telephone: (510) 350-9700
5 Facsimile: (510) 350-9701 Telephone: (202) 408-4600
amm@classlawgroup.com Facsimile: (202) 408-4699
6 zsw@classlawgroup.com ggraber@cohenmilstein.com
7 kputtieva@cohenmilstein.com
8
9
10
11
12 Attorneys for Plaintiffs and the Class
13
14
UNITED STATES DISTRICT COURT FOR THE
15
NORTHERN DISTRICT OF CALIFORNIA
16 SAN FRANCISCO DIVISION
17 CAT BROOKS and RASHEED SHABAZZ, Case No. 3:21-cv-1418-EMC-KAW
18 individually and on behalf of all others
similarly situated, DECLARATION OF ANDRE MURA AND
19 GEOFFREY GRABER IN SUPPORT OF
20 Plaintiffs, PLAINTIFFS’ MOTION FOR ATTORNEYS’
v. FEES, COSTS, AND SERVICE AWARDS
21
22 THOMSON REUTERS CORPORATION,
23 Date: February 13, 2024
Defendant. Time: 1:30 p.m.
24 Place: Courtroom 5, 17th Floor
Judge: Hon. Edward M. Chen
25
26
27
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DECLARATION OF ANDRE MURA & GEOFFREY GRABER IN SUPPORT OF PLAINTIFFS’
MOTION FOR FEES, COSTS, AND SERVICE AWARDS
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1 Plaintiffs’ counsel Andre Mura of Gibbs Law Group LLP and Geoffrey Graber of
2 Cohen Milstein Sellers & Toll PLLC, declare under penalty of perjury:
3 1. Andre Mura and Geoffrey Graber represent Plaintiffs in this certified class
4 action and respectfully submit this declaration in support of Plaintiffs’ Motion for Attorneys’
5 Fees, Costs, and Service Awards. We have personal knowledge of the facts set forth below
6 and if called as witnesses, could and would testify competently to them.
7 Complaint Allegations
8 2. This case arises from allegations concerning Thomson Reuters’ operation of its
9 online platform CLEAR. Plaintiffs allege that, through its “public records platform” CLEAR,
10 Thomson Reuters offers customers access to information about individuals across the United
11 States, including Californians. ECF No. 148-2 at 2.
12 3. Plaintiffs’ allegations detail that Thomson Reuters licenses access to large
13 volumes of information to power CLEAR from third party data providers. Id.at 2-6. It takes
14 this information, processes it, and creates “reports” on individuals, reports that can contain
15 a huge array of personal details about any particular Californian. Id. Some of the data is
16 otherwise public, and some of the data is not. Id. at 2.
17 Class Counsel’s Work in Securing the Proposed Settlement
18 4. During this litigation, our firms extensively investigated the facts, aggressively
19 litigated the case, and developed a strong understanding of the strengths and weaknesses
20 and value of the claims. This research included review of publicly available information
21 regarding the industry and consultation with investigators.
22 5. On December 3, 2020, Plaintiffs filed a putative class action complaint against
23 Thomson Reuters on behalf of Californians whose personal information was made available
24 through CLEAR. The complaint asserted that Thomson Reuters’ compilation and sale of
25 access to Californians’ personal information without their consent violated state privacy and
26 consumer protection law and unjustly enriched Thomson Reuters. ECF No. 1-1.
27 6. Thomson Reuters responded to the complaint by moving to dismiss. After full
28 briefing and oral argument, the Court granted and denied the motion in part. ECF No. 54.
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1 The Court dismissed Plaintiffs’ claims under California’s right of publicity (statutory and
2 common law), and Plaintiffs’ claim for violations of the “unlawful” prong of California’s
3 Unfair Competition Law. Id. The Court permitted Plaintiffs’ claim for injunctive relief for
4 violations of the “unfair” prong of the UCL to proceed, along with a claim for unjust
5 enrichment. Id.
6 7. Thomson Reuters then answered Plaintiffs’ complaint in September 2021. ECF
7 No. 60.
8 8. Plaintiffs filed an amended complaint conforming to the Court’s motion to
9 dismiss, and moved for certification of their remaining claims. ECF Nos. 123, 130. Both
10 parties prepared extensive expert testimony regarding class certification, and challenged the
11 admissibility of the opposing party’s experts. ECF No. 201.
12 9. In May and July 2023, the Court denied both parties’ motions to exclude the
13 other’s experts, and granted Plaintiffs’ Motion for Class Certification. ECF Nos. 206, 213. The
14 Court found that Plaintiffs had shown that their “right to control” theory showed a traceable
15 and redressable injury in fact, and that Plaintiffs’ remaining claims satisfied the requirements
16 of Rule 23(a) and 23(b), certifying both of Plaintiffs’ claims under Rule 23(b)(3), and
17 additionally certifying Plaintiffs’ claim for injunctive relief under California’s UCL under
18 Rule 23(b)(2). ECF No. 213.
19 10. Thomson Reuters petitioned the Ninth Circuit for interlocutory review of the
20 Court’s class certification order, ECF No. 223, which Plaintiffs opposed. The Ninth Circuit
21 denied Thomson Reuters’ motion. ECF No. 228.
22 11. Thus, at the time the parties subsequently reached a settlement, many of the
23 issues of law had been thoroughly briefed, vetted, and aired. The parties, therefore, had a
24 strong understanding of the legal issues and causes of action—framed by this Court’s
25 decisions and the Ninth Circuit’s—involved in this case.
26 12. At the time the parties reached a settlement, Plaintiffs had served nine
27 comprehensive sets of Request for Production of Documents on Thomson Reuters (“RFPs”).
28 Thomson Reuters provided responses to these ninety-seven RFPs, and indeed, as a result of
2
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1 extensive meeting and conferring between the parties, served many amended, supplemental
2 responses to take into account any agreements reached during the meet and confer process
3 and to conform the responses to the agreements reached regarding Thomson Reuters’
4 objections.
5 13. As a result of these considerable efforts, by the time of settlement, Thomson
6 Reuters had produced nearly 80,000 documents, totaling nearly 500,000 pages.
7 14. Plaintiffs also served, and received responses to, several comprehensive sets of
8 Interrogatories (totaling twenty-three in number). After extensive meeting and conferring,
9 Thomson Reuters agreed to amend its responses multiple times to provide supplemental
10 information important to Plaintiffs’ case.
11 15. Plaintiffs also served, and received responses to, sixty-five requests for
12 admission. In addition, Plaintiffs took seven fact depositions, three expert depositions, and
13 deposed Thomson Reuters pursuant to Rule 30(b)(6).
14 16. Plaintiffs also engaged in discovery motion practice before this Court, and
15 later, the Honorable Magistrate Judge Kandis A. Westmore. ECF Nos. 82, 96. For example,
16 this Court heard and ruled upon a dispute regarding Thomson Reuters’ production of its
17 data licensing agreements. ECF No. 82. This was critical, because the licensing agreements
18 would set out the universe of information available through CLEAR, and the entities that
19 supplied the data Thomson Reuters made available through its platform.
20 17. The parties also briefed issues relating to Plaintiffs’ ability to access and review
21 the CLEAR platform, and to Thomson Reuters’ obligations to produce supplemental
22 information as the case proceeded. ECF Nos. 120, 212.
23 18. Plaintiffs also responded to extensive discovery requests from Thomson
24 Reuters. Thomson Reuters served twenty-three interrogatories and fifty-eight RFPs. Named
25 Plaintiffs Cat Brooks and Rasheed Shabazz collected nearly 700,000 documents for Plaintiffs’
26 counsel to review in response to these discovery requests, and ultimately produced more
27 than 40,000 pages of responsive information. Plaintiffs’ counsel worked closely with both
28
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1 Named Plaintiffs to prepare responses to this written discovery, and to review and produce
2 the responsive information Thomson Reuters sought.
3 19. Thomson Reuters also deposed both Plaintiffs, each of whom spent time with
4 counsel preparing to testify.
5 20. Beyond fact discovery, the parties completed expert discovery related to class
6 certification (with Plaintiffs propounding two expert reports, and Thomson Reuters three).
7 Plaintiffs’ testifying experts at class certification were: Joseph Turow, Ph.D., a renowned
8 privacy scholar and the Robert Lewis Shayon Professor of Communication at the Annenberg
9 School for Communication at the University of Pennsylvania, and Terry Lloyd, CPA, CFA,
10 the Managing Director of Finance Scholars Group, Inc. ECF Nos. 206, 213.
11 21. Plaintiffs deposed Thomson Reuters’ three class certification rebuttal experts.
12 22. Thomson Reuters also deposed both of Plaintiffs’ class certification experts.
13 23. Further, Plaintiffs briefed and argued class certification and Daubert as it
14 related to the parties’ class certification experts and rebuttal experts. After obtaining class
15 certification, Plaintiffs opposed Thomson Reuters’ appeal to the Ninth Circuit pursuant to
16 Fed. R. Civ. P. 23(f).
17 24. The parties also prepared and exchanged merits expert reports, with Plaintiffs
18 preparing five primary expert reports for trial, and Thomson Reuters preparing three more.
19 Rebuttal and reply merits expert reports were scheduled to be prepared, but the settlement
20 obviated the need for further expert discovery.
21 25. Plaintiffs’ testifying experts on the merits were: Professor Turow; Mr. Lloyd;
22 Sarah Lamdan, J.D., the Deputy Director of the American Library Association (and a former
23 professor at CUNY School of Law); Becky Yoose, CIPP/US, CIPT, a library scientist and data
24 privacy consultant and the founder of LDH Consulting Services; and Sarah Butler, MA, the
25 Senior Managing Director of National Economic Research Associates, Inc.
26 26. Class Counsel also engaged in extensive, arms’ length settlement discussions
27 with Thomson Reuters before class certification and after. In particular, after class
28 certification, the parties held in-person meetings, video meetings, exchanged mediation
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1 statements, and exchanged settlement proposals. The proposed settlement was arrived at
2 only after both sides had the opportunity to be fully informed of the relative strengths and
3 weaknesses of their positions, litigation risks, and issues involving ability to pay. Settlement
4 was only reached after discovery was essentially complete in this action.
5 27. We and members of our respective law firms have been intimately involved in
6 this case. Gibbs Law Group LLP and its attorneys and staff have worked on this case since
7 before it was filed on December 3, 2020. Cohen Milstein Sellers Toll PLLC and its attorneys
8 and staff have worked on this case since October 2022. In addition, attorneys at Gupta
9 Wessler LLP, Justice Catalyst, and the Surveillance Technology Oversight Project (S.T.O.P.),
10 who also represent the named plaintiffs, worked to develop the case and assisted at various
11 points with the litigation, though neither Justice Catalyst nor S.T.O.P. is applying for fees
12 from the common fund.
13 28. Through this litigation, Class Counsel have faced substantial risks, including:
14 a. The risk of litigating against one of the largest and most sophisticated
15 law firms in the world with access to seemingly limitless resources.
16 b. The risk that the novel complaint would not withstand the motion to
17 dismiss.
18 c. The risk that Defendant would, and in fact has, vehemently contested
19 Plaintiffs’ claims.
20 d. The risk that Defendant would prevail on its arguments at any phase of
21 this litigation.
22 e. The risk of not achieving class certification.
23 f. The changing landscape of the law with respect to proving damages and
24 class actions generally.
25 g. The risk of an unfavorable ruling at summary judgment eliminating one
26 or both of Plaintiffs’ remaining claims.
27 h. The risk that Plaintiffs’ novel legal claims, even if successful at trial,
28 would be overturned on appeal.
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1 Attorneys’ Fees
2 29. The hourly rates for the attorneys, paralegals, and law clerks at Gibbs Law
3 Group are as follows: partner hourly rates range from $730 to $915; counsel hourly rates
4 range from $795 to $850; associate hourly rates range from $445 to $665; and litigation
5 assistants’ rates range from $220 to $240. The total number of hours spent by Gibbs Law
6 Group during the relevant time period based on contemporaneous time records is 7,331.2
7 hours, with a corresponding lodestar of $4,543,362.50. This does not include any attorneys
8 and staff who billed less than 50 hours, and it does not include the work of contract attorneys
9 who assisted in document review, which totals 1,444.40 hours. Courts have accepted the rates
10 of Gibbs Law Group LLP attorneys in this District, including in In Re: Robinhood Outage Litig.,
11 No. 3:20-cv-01626-JD, ECF No. 191-6 at Ex. A (N.D. Cal. Mar. 27, 2023) (reporting $835 per
12 hour for Mura; $775 per hour for Troutman), ECF No. 203 at ¶ 7 (N.D. Cal. Jul. 28, 2023)
13 (finding rates reasonable); In re Zoom Video Commc’ns, Inc. Priv. Litig., No. 3:20-cv-02155-LB,
14 2022 WL 1593389, at *11 (N.D. Cal. Apr. 21, 2022) (accepting rates of Andre Mura, Amanda
15 Karl, and Jeff Kosbie as reasonable), ECF No. 218-5 at 6 (N.D. Cal. Jan. 28, 2022) (reporting
16 $775 per hour for Mura; $465 per hour for then-associate Karl; and $510 for Kosbie); Tyler
17 Barnett PR, LLC v. Facebook, Inc., No. 4:16-cv-06232-JSW, ECF Nos. 204-3 at 2 (N.D. Cal. Jan.
18 15, 2020) (reporting $710 per hour for Stein), 211 at 4 (N.D. Cal. June 26, 2020) (finding rates
19 reasonable).
20 Years of
Timekeeper Title Rate Hours Lodestar
21 Practice
22 Brooks,
Associate 2 $445 145.6 $64,792.00
23 Delaney
24 Graham,
Counsel 20 $795 77.4 $61,533.00
25 Kristy
26 Jensen,
Associate 4 $490 740.5 $362,845.00
27 Hanne
28
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1 Karl,
Partner 9 $730 102.2 $74,606.00
2 Amanda
3 Kincaid, Litigation
N/A $240 92.6 $22,224.00
4 Lindsey Assistant
5 Kosbie, Jeff Associate 8 $665 168.6 $112,119.00
6 Mura, Andre Partner 19 $915 1,095.3 $1,002,199.50
7 Norton, Litigation
N/A $220 153.8 $33,836.00
8 Gillian Assistant
9 Stein, Dave Partner 15 $895 129.5 $115,902.50
10 Troutman,
Counsel 20 $850 938.6 $797,810.00
11 Mark
12 Wald, Zeke Associate 3 $490 3,467.8 $1,699,222.00
13 Zeman, Amy Partner 13 $895 219.3 $196,273.50
14 Total: 7,331.2 $4,543,362.50
15
16 30. The hourly rates for the attorneys, paralegals, and law clerks at Cohen Milstein
17 Sellers & Toll PLLC are as follows: partner hourly rates range from $980 to $1050; associate
18 hourly rates are $675; investigator hourly rates are $645; and paralegal hourly rates are $380.
19 The total number of hours spent by Cohen Milstein during the relevant time period based
20 on contemporaneous time records is 1,396.2 hours, with a corresponding lodestar of
21 $910,525.00. Courts that have accepted the rates of Cohen Milstein Sellers & Toll attorneys
22 include: Prescott v. Reckitt Benckiser LLC, 5:20-cv-02101 (N.D. Cal.), ECF Nos. 197-1 at 4
23 (setting out billing rates), 201 at 2 (approving fee request); Ariza et al v. Luxottica Retail North
24 America, 1:17-cv-05216 (E.D.N.Y.), ECF Nos. 356-1 at 3-4 (setting out billing rates), 375 at 29
25 (approving fee request).
26 Timekeeper Title Years of Practice Rate Hours Lodestar
27
Clarke, Suzanne Investigator N/A $645 1.3 $838.50
28
Graber, Geoffrey Partner 24 $1,050 117.5 $123,375.00
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1 Hamdan,
Paralegal N/A $380 8 $3,040.00
2 Shireen
3 Horowitz,
Paralegal N/A $380 308.7 $117,306.00
4 Jennifer E.
5 McCubbin, Erin Paralegal N/A $380 12.3 $4,674.00
6 Nugent, Victoria
Partner 25 $980 91.4 $89,572.00
7 S.
8 Puttieva, Karina Associate 7 $675 834.1 $563,017.50
9 Shea, Caitlin Paralegal N/A $380 22.9 $8,702.00
10 Total: 1396.2 $910,525.00
11
12 31. The hourly rates for the two attorneys at Gupta Wessler LLP who worked on
13 this case are: $1,100 for a principal (partner) who is the head of the San Francisco office; and
14 $800 for an associate with ten years of experience. In this case, however, Gupta Wessler is
15 requesting a discounted hourly rate of $915 for the partner, and $665 for the associate,
16 consistent with the rates of other partners and associates in this litigation and in this District.
17 The total number of hours spent by Gupta Wessler during the relevant time period based on
18 contemporaneous time records is 124 hours, with a corresponding lodestar of $105,760.00.
19 Years of
Timekeeper Title Rate Hours Lodestar
20 Practice
21 Jennifer
Principal 10 $915 93.2 $85,278.00
22 Bennett
23 Neil Sawhney Associate 10 $665 30.8 $20,482.00
24 Total: 124.0 $105,760.00
25
26
32. The total hours spent across Gibbs Law Group LLP, Cohen Milstein Sellers &
27
Toll PLLC, and Gupta Wessler LLP during this litigation to date is 8,851.4, with a
28
corresponding lodestar of $5,559,647.50. The following table reflects the breakdown of these
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DECLARATION OF ANDRE MURA & GEOFFREY GRABER IN SUPPORT OF
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1 total hours across 14 task code categories, which are modeled on the categories adopted in
2 In re: Soc. Media Adolescent Addiction/Pers. Injury Prods. Liab. Litig., No. 22-md-03047-YGR
3 (N.D. Cal. Mar. 15, 2023), ECF No. 190 at Ex. A. Those categories are as follows:
4 a. “Case management duties” covers the general administrative
5 leadership responsibilities associated with organizing and managing
6 this litigation, such as preparing case management statements.
7 b. “Leadership calls and meetings” covers contemporaneous meetings
8 between lead counsel and supporting counsel directing the litigation.
9 c. “Administrative” covers organizational tasks such as monitoring
10 expenses and updating calendars.
11 d. “Court appearances and preparation” covers counsel’s time preparing
12 for and attending hearings.
13 e. “Pleadings/briefing/pre-trial motions/legal memoranda” covers
14 research and drafting time spent for specific pleadings, briefs, motions,
15 or similar legal writing, time spent reviewing, analyzing, and
16 summarizing filings and orders of the Court, and similar legal research
17 and writing tasks. This includes, for example, preparing memoranda on
18 class certification issues, drafting and editing the class certification brief,
19 researching and writing specific discovery briefs, and so on.
20 f. “Research” covers legal research time that is cross-category and not
21 specifically affiliated with a specific in-progress brief, filing, or
22 memorandum.
23 g. “Litigation strategy and analysis” covers time spent on strategy and
24 analysis to support the advancement of the case, including on the merits
25 and class certification.
26 h. “Document review and analysis” covers review of document discovery
27 produced in this litigation and analysis as to the import of that
28 documentary evidence.
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1 i. “Discovery” covers most discovery related tasks, including discovery
2 for class certification and the merits
3 j. “Experts” covers communication with and retention of experts, time
4 spent on expert reports and expert discovery (documentary and
5 depositions), and time spent working with experts preparing for
6 Daubert briefing and hearings, and the like.
7 k. “Settlement” covers strategic discussions between counsel regarding
8 settlement, participation in mediations and drafting mediation
9 statements, preparation of term sheets and a master settlement
10 agreement, discussions with the settlement administrator, preparation
11 of class notice, and so on.
12 l. “Trial preparation” covers time spent preparing for trial in this
13 litigation.
14 m. “Appeal” covers tasks related to appeals, including time spent
15 reviewing and opposing Thomson Reuters’ 23(f) appeal of the Court’s
16 order granting class certification.
17 n. “Miscellaneous” covers time that could not be accurately categorized
18 into one of the more specific categories described above.
19 33. The breakdown per category across all firms is as follows:
20 Task Hours Spent Lodestar
21 Case management duties 13.6 $11,888.50
22 Leadership calls/meetings 66.5 $44,645.50
23 Administrative 36 $18,001.00
24 Court appearances 62.7 $49,638.50
25 Pleadings/briefing/pre-trial
1,844.1 $1,098,397.00
26 motions/legal memoranda
27 Research 307.5 $159,306.00
28 Litigation strategy & analysis 201.6 $150,665.50
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1 Document review & analysis 537.5 $288,047.00
2 Discovery 3,244.9 $2,123,816.00
3 Experts 1,886.2 $1,144,871.50
4 Settlement 615.7 $446,074.50
5 Trial preparation 0 $0
6 Appeal 35.1 $24,296.50
7 Miscellaneous 0 $0
8 Total: 8,851.4 $5,559,647.50
9
10 34. The breakdown per biller per law firm is provided below in Exhibit 1.
11 Costs and Expenses
12 35. The total unreimbursed costs and expenses incurred during this litigation are
13 $670,885.29. Co-Lead Counsel have previously submitted a breakdown of these costs into
14 particular cost categories to the Court. ECF No. 250 at 6. We provide here an updated
15 summary of unreimbursed costs and expenses for the Court’s review.
16
Total Accounting Expenses
17 Discovery Vendor $ 187,348.50
18 Experts $ 268,033.75
Mediation $ 106,853.00
19 Westlaw / Case Research $ 25,994.42
20 Depositions $ 57,334.97
21 Copying and service delivery charges $ 4,052.55
Travel & hotels $ 19,345.44
22 Filing, Pacer, and document download fees $ 456.08
23 Meals $ 1,466.58
Total $ 670,885.29
24
25
36. The costs and expenses incurred in this action were advanced by Gibbs Law
26
Group LLP in the amount of $358,949.17, Cohen Milstein Sellers & Toll PLLC in the amount
27
of $201,758.12, and Justice Catalyst, in the amount of $110,178.00. Receipts are available upon
28
the Court’s request.
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1
2 We declare under penalty of perjury that the foregoing is true and correct to the best
3 of our knowledge. Executed on October 25, 2024.
4
5 /s/ Andre M. Mura
Andre M. Mura
6
Gibbs Law Group LLP
7
/s/ Geoffrey Graber
8 Geoffrey Graber
9 Cohen Milstein Sellers & Toll PLLC
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1 ATTESTATION
2 Pursuant to Civil Local Rule 5-1(i)(3), I attest that concurrence in the filing of this
3 document has been obtained from the other signatory.
4
5 /s/ Andre M. Mura
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EXHIBIT 1
Exhibit 1
Case 3:21-cv-01418-EMC Document 264-1 Filed 10/25/24 Page 16 of 17
Category Codes
(1) Case management duties (2) Leadership calls/meetings (3) Administrative (4) Court Appearances &
Preparation
(5) Pleadings/briefing/pre-trial (6) Research (7) Litigation strategy (8) Document review &
motions/legal memoranda & analysis analysis
(9) Discovery (10) Experts (11) Settlement (12) Trial Preparation
(13) Appeal (14) Miscellaneous
Name Title (Years) 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Total Rate Lodestar
Brooks,
Associate (2)
Delaney 0.0 0.0 0.0 0.0 127.3 11.2 0.0 0.0 7.1 0.0 0.0 0.0 0.0 0.0 145.6 $445 $64,792.0
Graham,
Counsel (20)
Kristy 0.0 0.0 0.0 0.0 51.5 0.0 0.0 0.0 25.9 0.0 0.0 0.0 0.0 0.0 77.4 $795 $61,533.0
Jensen,
Associate (4)
Hanne 0.0 20.8 0.1 2.3 261.4 19.8 32.9 0.1 123.0 263.6 16.5 0.0 0.0 0.0 740.5 $490 $362,845.0
Karl,
Partner (9)
Amanda 0.0 0.0 0.1 0.0 75.9 17.5 0.2 0.0 8.5 0.0 0.0 0.0 0.0 0.0 102.2 $730 $74,606.0
Kincaid, Litigation
Lindsey Assistant 0.0 0.0 5.3 0.0 2.0 0.0 0.0 46.0 13.1 22.9 3.3 0.0 0.0 0.0 92.6 $240 $22,224.0
Kosbie,
Associate (8)
Jeff 0.0 4.4 0.3 2.2 43.7 0.0 0.0 0.0 118.0 0.0 0.0 0.0 0.0 0.0 168.6 $665 $112,119.0
Mura,
Partner (19)
Andre 9.4 10.0 3.5 42.6 234.4 2.3 87.9 1.2 336.8 143.5 215.9 0.0 7.8 0.0 1095.3 $915 $1,002,199.5
Norton, Litigation
Gillian Assistant 0.0 0.0 0.0 0.0 0.0 0.0 0.0 104.1 34.0 15.7 0.0 0.0 0.0 0.0 153.8 $220 $33,836.0
Stein,
Partner (15)
Dave 0.0 0.0 0.0 0.0 1.7 0.0 3.7 0.0 51.0 73.1 0.0 0.0 0.0 0.0 129.5 $895 $115,902.5
Troutman,
Counsel (20)
Mark 0.0 0.5 0.0 0.0 46.2 12.7 0.0 152.6 670.4 47.4 8.8 0.0 0.0 0.0 938.6 $850 $797,810.0
Wald,
Associate (3)
Zeke 0.0 3.6 4.1 13.3 868.8 196.7 30.7 190.7 1173.3 724.3 252.9 0.0 9.4 0.0 3467.8 $490 $1,699,222.0
Zeman,
Partner (13)
Amy 0.0 1.3 3.0 0.0 10.2 0.0 0.0 0.0 34.5 165.1 5.2 0.0 0.0 0.0 219.3 $895 $196,273.5
Clarke,
Investigator
Suzanne 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.8 0.5 0.0 0.0 0.0 0.0 1.3 $645 $838.5
Graber,
Partner (24)
Geoffrey 0.8 2.6 0.0 0.0 0.0 0.0 2.3 0.0 1.5 29.5 80.8 0.0 0.0 0.0 117.5 $1,050 $123,375.0
Exhibit 1
Case 3:21-cv-01418-EMC Document 264-1 Filed 10/25/24 Page 17 of 17
Hamdan,
Paralegal
Shireen 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 8.0 0.0 0.0 0.0 0.0 8.0 $380 $3,040.0
Horowitz,
Paralegal
Jennifer E. 0.0 4.9 17.6 0.0 4.4 34.2 2.3 0.0 110.9 133.6 0.8 0.0 0.0 0.0 308.7 $380 $117,306.0
McCubbin,
Paralegal
Erin 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 12.3 0.0 0.0 0.0 12.3 $380 $4,674.0
Nugent,
Partner (25)
Victoria, S. 0.5 6.6 1.0 0.0 6.4 0.0 8.1 3.0 35.1 30.7 0.0 0.0 0.0 0.0 91.4 $980 $89,572.0
Puttieva,
Associate (7)
Karina 2.9 11.8 0.3 2.3 36.2 5.5 26.1 39.8 481.6 211.8 15.8 0.0 0.0 0.0 834.1 $675 $563,017.5
Shea,
Paralegal
Caitlin 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 11.9 11.0 0.0 0.0 0.0 0.0 22.9 $380 $8,702.0
Bennett, Principal
Jennifer (10) 0.0 0.0 0.7 0.0 64.3 3.2 7.4 0.0 7.3 4.3 3.4 0.0 2.6 0.0 93.2 $915 $85,278.0
Sawhney, Associate
Neil (10) 0.0 0.0 0.0 0.0 9.7 4.4 0.0 0.0 0.2 1.2 0.0 0.0 15.3 0.0 30.8 $665 $20,482.0
Total: 13.6 66.5 36.0 62.7 1844.1 307.5 201.6 537.5 3244.9 1886.2 615.7 0.0 35.1 0.0 8851.4 $5,559,647.50
Exhibit 1
File and source
- File
- gov.uscourts.cand.374304.264.1.pdf
- Size
- 423,096 bytes
- SHA-256
- 0f26b902f8dce0ec06d4d4502b8ca8f5be5b234896afe43f61c2c35e551f316e
- Original
- PACER (login required)