From: Darren Indyke

From: Darren Indyke To: "jeffrey E." <[email protected]> Subject: Privileged and Confidential Date: Wed, 11 Jun 2014 00:12:32 +0000 Attachments: Invoice_5-28-14.pdf; Invoice,_6-2-14.doc Marty's and Richard Strafer's invoices are attached. Richard billed 36.25 hours ($19,937.50) for the Reply to Cassell's opposition to our motion for the protective order, which he told me on the phone when I was with you at your house on May 19 would take between 10 and 20 hours. Richard's $12,787.50 prior balance relates to Richard's work in drafting the initial motion for the protective order, which you previously approved, but I did not pay because I wanted to first receive Richard's final bill after he prepared the Reply to Cassell's opposition to our motion for the protective order before we made any further payment, (Note that Richard is billing $7K more for his Reply than he billed for the original motion for the protective order.) I do not believe that Richard's time makes sense. We got the first "rough" draft from Richard on May 20th, the day after he told me that he would bill 10 to 20 hours. Richard billed 12.5 hours of drafting and research on May 18 and May 19. Then another 5.25 on May 20. That is 17.75 hours on a "rough" draft, not including the his 5.25 hours he billed on May 16 and 17 for reading the motion for protective order that he himself drafted and cassell's response thereto, as well as Marty's emails containing the ideas for the reply. (That is 5.25 hours to reread a brief he drafted and the opposing brief and some emails from Marty?) That is crazy. Richard then billed another 13 hours after that on revisions. Doesn't make sense. Richard will claim that he was within the time he told me (not including his initial 5.25 hours before he started drafting) until we came back requiring so many Edits. I have not doubt that he will point out that there were a total of 13 drafts of the Reply. But Marty was doing much of the editing. So, how does Richard have 13 hours of post rough draft edits. Both Richard and Marty were traveling and both were plugging in and out, which i think contributed to excess hours. Even so, Marty's time was 10 hours less than Richard's. Marty's bill is for 26.25 hours of his time from May 6 to June 1 and consists of time in reviewing Cassells' filings that sought clarification abou obligation to file unredacted summary judgment pleadings and reviewing Cassells' opposition to ourt n t icia protective order. Marty's time also includes drafting, editing and working with Richard on the Reply to Cassell's opposition. Marty does not break down his time on a daily basis. But Marty did not draft the Reply from scratch. He read briefs and then edited Richard's work, as well as incorporated comments from me. That does not seem like it should take 26.25 hours. I would like to challenge both of them, but Marty got pretty miffed when I challenged the 27.5 hours reflected in Richard's $16K bill for the work Richard did on the motion for the Stay. I just want to make sure you are ok with me taking this up with both Marty and Richard. DARREN K. INDYKE DARREN K. INDYKE, PLLC 575 Lexington Avenue, 4th Floor EFTA01186492 New York, New York 10022 email: **** The information contained in this communication is confidential, may be attorney-client privileged, and is intended only for the use of the addressee. It is the property of Darren K. Indyke, PLLC. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail, and destroy this communication and all copies thereof, including all attachments. Copyright of Darren K. Indyke, PLLC - O 2014 Darren K. Indyke, PLLC — All rights reserved. ***************************** ****** ************** ***************************************** EFTA01186493