Exhibit C: Proposed Time-Keeping and Expense Protocols, Joseph Saveri Law Firm (Dkt. 252-4, S.D. Fla.)

Summary

Exhibit C (Document 252-4) in Case 1:21-md-02989-CMA, entered April 26, 2021 (5 pages): the Proposed Time-Keeping and Expense Protocols that the Joseph Saveri Law Firm, LLP would implement if appointed Interim Lead Class Counsel for the proposed Antitrust Class. The protocols require Lead Counsel's authorization before any other firm works on the matter, monthly time and expense reports within fourteen days of each month's end with disputes raised within 30 days, routine audits by a Certified Public Accountant at no cost to the Class, contemporaneous task-by-task records with no block-billing, and usual and customary billing rates. Document reviewers are capped at $240.00 per hour, air travel at a prevailing economy plus class rate, and per diem meals at $75.00 per day domestic and $105.00 per day international.

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Case 1:21-md-02989-CMA Document 252-4 Entered on FLSD Docket 04/26/2021 Page 1 of 5




                         Exhibit C
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           If appointed to serve as Interim Lead Class Counsel for the proposed Class (the

    “Antitrust Class”), the Joseph Saveri Law Firm, LLP (“Lead Counsel”) will implement the

    following protocols to ensure the efficient prosecution of this action and the ability to present the

    Court with clear and definitive records concerning fees and expense.

                   PROPOSED TIME-KEEPING AND EXPENSE PROTOCOLS

    I.     WORK AUTHORIZATION IN THIS LITIGATION

           A.      Lead Counsel Authorization. No firm other than Lead Counsel will perform

                   work on this matter without the prior authorization of the Court or Lead Counsel.

           B.      Review by Lead Counsel. While all attorneys have an obligation to keep

                   themselves informed about the litigation, Lead Counsel will deem only those

                   attorneys designated by Lead Counsel to review or summarize pleadings, orders,

                   and communications to have worked for the common benefit of the proposed

                   Antitrust Class whose time will be considered for submission to the Court for

                   possible payment or lodestar analysis in the event that a common fund is

                   established for the benefit of the proposed Antitrust Class.

           C.      Submission Timeline. If the Court or Lead Counsel authorizes additional firms

                   to work on this case, within fourteen days of the end of each calendar month, any

                   firm that has performed authorized work shall transmit time entries to Lead

                   Counsel that conforms with the requirements herein. Monthly time and expense

                   reports will be reviewed each month by Lead Counsel and may be returned within

                   30 days to the firm submitting such report along with an explanation as to why

                   time or an expense has been rejected. If a firm disputes rejected time or a rejected




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               expense, it must raise that dispute within 30 days of return of the report. Any

               issue timely raised concerning rejected time or a rejected expense may be deferred

               until there is a settlement or judgment and addressed 45 days before the

               submission of a fee application in this case.

          D.   Subject to Review. All time and expense submissions will be subject to review by

               Lead Counsel, and, if requested, the Court. Lead Counsel has retained and will

               employ a Certified Public Accountant, at no cost to the Class, who will routinely

               audit time and expense reports which can be submitted on a quarterly basis to the

               Court for review.

    II.   TIME SUBMISSION DETAILS

          A.   Contemporaneous Records. All timekeepers must record time

               contemporaneously with the work performed.

          B.   Reporting Increments. Block-billing is not permitted. All time must be recorded

               by task. Each timekeeper is responsible for specifying the amount of time spent for

               each task performed.

          C.   Detailed Descriptions. Timekeepers must contemporaneously record specific

               and detailed description of the work performed. The subject matter and other

               counsel involved in any task must be included in the description.

          D.   Submission to Lead Counsel. All timekeepers should input time into an

               electronic timekeeping system by the end of each day; or, if an attorney records

               time through handwritten notes, the attorney or support staff should input the




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               handwritten entries into timekeeping software by the close of each calendar

               month. Time spent entering time is not billable to the proposed Class.

         E.    Non-Duplicative Work. Time reported must be reasonable and necessary and

               shall not exceed the fair value of the services performed. Unnecessarily

               duplicative work by multiple lawyers in the same firm will not be compensable and

               should not be submitted. Barring unusual circumstances, only one attorney will

               defend a deposition, and no more than two attorneys will attend when taking a

               deposition.

         F.    Billing Rates. Professional time is to be reported using the usual and customary

               billing rates current for that person at the time the work was performed.

         G.    Court Attendance. Lead Counsel will take the lead on most appearances in Court

               but is expected to provide opportunities for younger lawyers to appear in Court.

               Attendance or appearance in Court will be compensable only when approved in

               advance by Lead Counsel.

         H.    Contract Attorneys/Document Review. No contract attorneys should be

               assigned to review documents in this case without prior written approval from

               Lead Counsel. The hourly rate for all document reviewers will be their usual and

               customary hourly rate but shall not exceed $240.00 per hour, and counsel shall

               maintain a record of actual costs incurred in retaining contract attorneys. No

               contract lawyer should spend more than 8 hours per day reviewing documents.

               Any time spent above 8 hours a day shall not be compensable unless prior

               approval is received from Lead Counsel.




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    III.   EXPENSE REPORTING DETAILS

           A.   Receipts. The original receipts for all expenses incurred that substantiate the

                information in monthly expense reports must be maintained by each firm and

                timely submitted if requested by the Court or Lead Counsel.

           B.   Arrears. Any time or expenses submitted more than one month in arrears will not

                be considered or included in any compilation of compensable time or expenses

                and will be disallowed, except for good cause shown and with approval of the

                Court or Lead Counsel.

           C.   Airfare. Attorneys will only be reimbursed for air travel at a prevailing economy

                plus class rate at the time travel is booked for all domestic flights. It shall be the

                obligation of any attorney submitting reimbursement requests for air travel to

                maintain records showing such rates.

           D.   Per Diem Expenses. Reasonable per diem expenses will not exceed $75.00 per

                day per person for domestic meals and $105.00 per day per person for

                international meals.

           E.   Travel Accommodations. Counsel will select reasonable hotel accommodations

                and restaurants.




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