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Time and Expense Records Texas Government Code Sec. 2254.104 PRIVILEGED AND CONFIDENTIAL
Firm Name: Keller Postman LLC
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DateFirst NameLast NameTask DescriptionTask Type (Drop down)Hours BilledRoleRateLodestarFee with Multiplier
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2/1/2022NickLarryReviewing and revising draft petition, researching re: same, and emailing Bash and Dravillas re sameRevising/Editing2.3Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$2,173.50$8,694.00
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2/1/2022ZinaBashReview McKool's draft petition and begin taking notes regarding revisions.Revising/Editing1.5Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$1,417.50$5,670.00
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2/2/2022NickLarryReviewing docket entries from Facebook biometrics class action and making further revisions to draft petition,Revising/Editing3Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$2,835.00$11,340.00
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2/2/2022NickLarryZoom mtg with Bash and Dravillas to discuss petition revisions and delegation of further work revising petition, sending followup emails containing materials referenced during call.Meetings1.4Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$1,323.00$5,292.00
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2/2/2022AlexDravillasCall with Z. Bash and N. Larry re petition strategyCalls1.3Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$1,228.50$4,914.00
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2/2/2022AlexDravillasDraft/revise petitionRevising/Editing4Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$3,780.00$15,120.00
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2/2/2022AlexDravillasResearch filings in analogous court proceedingsResearch3.8Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$3,591.00$14,364.00
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2/2/2022ZinaBashDiscuss with S. Cowles and B. Schuelke the timing and substance of the petition and obtaining CID materials.Meetings0.4Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$378.00$1,512.00
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2/2/2022ZinaBashDiscuss with B. Schuelke and N. Larry B. Schuelke’s impressions of the CID responses and filings in the Facebook case in Illinois.Meetings0.7Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$661.50$2,646.00
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2/2/2022ZinaBashDiscuss draft petition with N. Larry and A. Dravillas, and next steps to revise the petition by adding new legal theories, allegations, and requests for relief.Meetings1.3Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$1,228.50$4,914.00
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2/2/2022ZinaBashResearch Texas law surrounding CUBI to revise petition; review correspondence from N. Larry and A. Dravillas about their research and findings; review early filings in the publicly available record from the Illinois BIPA case against Facebook to inform how we draft the petition.Research6.3Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$5,953.50$23,814.00
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2/3/2022NickLarryResearching whether constructive consent can count as informed consent under TX law, for petition and case strategy generallyResearch0.2Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$189.00$756.00
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2/3/2022NickLarryEmailing Bash and Dravillas regarding framing of draft petition and FB's informed consent arguments and handling in IL class action briefing.Email0.3Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$283.50$1,134.00
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2/3/2022AlexDravillasResearch on what constitutes "informed" for informed consent in evaluating claim against FacebookResearch0.8Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$756.00$3,024.00
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2/3/2022NickLarryReviewing Facebook BIPA class action docket and pulling salient facts for draft petitionRevising/Editing4.9Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$4,630.50$18,522.00
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2/3/2022NickLarryReviewing draft petition and providing feedback by email to Bash and DravillasRevising/Editing1.9Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$1,795.50$7,182.00
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2/3/2022AlexDravillasResearch minors' capacity to contract under TX law for Facebook petition claimsResearch1Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$945.00$3,780.00
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2/3/2022AlexDravillasResearch/review of analogous case docket for inclusion of info for claims in petitionResearch1.7Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$1,606.50$6,426.00
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2/3/2022AlexDravillasResearch Defendant biometric disclosures over time for inclusion in petitionResearch1.1Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$1,039.50$4,158.00
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2/3/2022AlexDravillasDraft petition segments re timeline of disclosures to customers, technology, disclosures to third partiesDrafting2.4Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$2,268.00$9,072.00
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2/3/2022AlexDravillasDraft/research claims related to Instagram for petitionDrafting1.1Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$1,039.50$4,158.00
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2/3/2022ZinaBashDiscuss with M. Sutarwalla the drafting of the petition and next steps.Meetings0.4Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$378.00$1,512.00
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2/3/2022ZinaBashResearch public record in Illinois BIPA case against Facebook to inform drafting of our petition.Research2.4Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$2,268.00$9,072.00
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2/4/2022AlexDravillasResearch ability of OAG to bring parens contract claimsResearch0.4Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$378.00$1,512.00
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2/4/2022MarissaSpaldingReview obtaining Pro Hac Vice in Marshall TX per Z. Bash. Review documents in Facebook Biometric folders from Adrian to ensure collection of docket documents adheres with materials we need to collect. Discussion with Andy regarding next steps for the docket re BIPA.Revising/Editing1.9Paralegals including eDiscovery Professionals$200.00$380.00$1,520.00
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2/4/2022NickLarryPreparing summary of Facebook BIPA docket/facts for Bash and Dravillas, to assist with drafting of petitionDrafting1.5Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$1,417.50$5,670.00
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2/4/2022NickLarryResearching for and drafting section of petition explaining uses and pitfalls of facial recognition technologyDrafting1.5Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$1,417.50$5,670.00
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2/4/2022NickLarryZoom call with Bash and Dravillas to discuss strategic changes to petition, review comments on prior draft, and discuss next stepsMeetings1.3Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$1,228.50$4,914.00
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2/4/2022NickLarryCall with Bash and Brad Schuelke re: petition and treatment Facebook's recognition process under CUBI as opposed to BIPACalls0.5Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$472.50$1,890.00
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2/4/2022NickLarryReviewing CID production to inform petition draftingRevising/Editing1.5Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$1,417.50$5,670.00
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2/4/2022AlexDravillasRevise petitionRevising/Editing0.4Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$378.00$1,512.00
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2/4/2022AlexDravillasResearch potential count for identity theft protectionResearch0.4Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$378.00$1,512.00
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2/4/2022AlexDravillasDraft counts to the petitionDrafting1.8Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$1,701.00$6,804.00
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2/4/2022AlexDravillasReview analogous docketOther0.3Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$283.50$1,134.00
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2/4/2022AlexDravillasResearch wrap agreements under TX lawResearch0.2Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$189.00$756.00
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2/4/2022AlexDravillasCall with Z. Bash and N. Larry re petition strategyCalls1.3Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$1,228.50$4,914.00
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2/4/2022AlexDravillasReview CID and OAG materials for purposes of revising the petitionDevelopment0.5Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$472.50$1,890.00
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2/4/2022ZinaBashResearch public record in Illinois BIPA case against Facebook to inform drafting of our petition; review and revise portions of petition.Revising/Editing4.5Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$4,252.50$17,010.00
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2/5/2022NickLarryEmailing with Bash and Dravillas re edits to draft complaintEmail0.4Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$378.00$1,512.00
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2/5/2022NickLarryRevising draft petitionRevising/Editing3.3Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$3,118.50$12,474.00
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2/5/2022AlexDravillasCorrespondence with cocounsel re revisions to petitionEmail0.5Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$472.50$1,890.00
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2/5/2022ZinaBashReview and revise initial draft petition.Revising/Editing5.3Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$5,008.50$20,034.00
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2/6/2022NickLarryRevising petitionRevising/Editing1.5Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$1,417.50$5,670.00
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2/6/2022NickLarryEmailing with Dravillas and Bash re edits to the petition.Email0.3Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$283.50$1,134.00
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2/6/2022AlexDravillasPetition revisions and correspondence re sameRevising/Editing1.8Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$1,701.00$6,804.00
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2/6/2022AshleyKellerEdit CUBI Texas petitionRevising/Editing4.1Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$3,874.50$15,498.00
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2/6/2022ZinaBashResearch for CUBI petition, including reviewing new CID materials, and review and revise draft.Research4.8Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$4,536.00$18,144.00
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2/7/2022NickLarryResearching pleading requirements for materiality/reliance under DTPA and emailing Bash and Dravillas re sameResearch0.3Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$283.50$1,134.00
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2/7/2022NickLarryReviewing petition feedback re: Instagram facial recognition disclosures, researching further, discussing with Bash and Dravillas, and emailing Bash and Dravillas a summary of theory of liability re: Instagram for draft petition.Email1.6Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$1,512.00$6,048.00
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2/7/2022MarissaSpaldingDraft Motion for PHV for Non-Resident Attorney (Brooke). Draft Declaration of Zina to accompany Motions. Draft Motion for PHV for Non-Resident Attorney (Alex).Drafting1.6Paralegals including eDiscovery Professionals$200.00$320.00$1,280.00
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2/7/2022NickLarryRevising draft petition sections regarding opt-out functionality and InstagramRevising/Editing0.7Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$661.50$2,646.00
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2/7/2022NickLarryReviewing prior docket notes and supplementing with redacted materials from CID productionOther0.6Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$567.00$2,268.00
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2/7/2022AlexDravillasCall with Z. Bash and N. Larry re petition strategyCalls0.9Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$850.50$3,402.00
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2/7/2022AlexDravillasReview/revise petitionRevising/Editing0.9Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$850.50$3,402.00
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2/7/2022AlexDravillasInternal correspondence re petitionEmail0.4Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$378.00$1,512.00
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2/7/2022AlexDravillasOAG CUBI petition kickoff and strategy callCalls0.8Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$756.00$3,024.00
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2/7/2022AshleyKellerEdit CUBI Texas petitionRevising/Editing3.8Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$3,591.00$14,364.00
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2/7/2022ZinaBashParticipate on call with N. Larry and A. Dravillas to discuss updating Instagram portion of draft petition.Calls0.8Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$756.00$3,024.00
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2/7/2022ZinaBashParticipate on call with OAG, McKool, and KL to introduce ourselves and plan next steps for revising and ultimately finalizing the petition.Calls0.5Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$472.50$1,890.00
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2/7/2022ZinaBashReview and revise draft petition.Revising/Editing2.2Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$2,079.00$8,316.00
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2/8/2022MarissaSpaldingResearch filing in the District Court 71st Judicial District Harrison County, TX. Review edits to Motion for Pro Hac Vice from Alex. Draft Motions for PHV for Nick, Ashley and Warren. Review and cite check drafted petition.Revising/Editing3.5Paralegals including eDiscovery Professionals$200.00$700.00$2,800.00
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2/8/2022NickLarryCall with Schuelke, Robinson, Bash, and Dravillas re disclosure allegations and scope of capture claimsCalls1Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$945.00$3,780.00
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2/8/2022NickLarryEmailing with Bash and Dravillas re non-redacted citations for allegations in petitionEmail0.4Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$378.00$1,512.00
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2/8/2022NickLarryReviewing McKool edits to petition and emailing Bash and Dravillas thoughts re those changes, Instagram LLC corporate structure and disclosure allegationsEmail0.4Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$378.00$1,512.00
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2/8/2022NickLarryEmailing with Bash and Dravillas re: Instagram allegations citing to redacted portions of petition, and disclosure allegations against InstagramEmail0.3Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$283.50$1,134.00
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2/8/2022AlexDravillasReview pro hac vice motion to participate in case.Revising/Editing0.1Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$94.50$378.00
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2/8/2022AlexDravillasCall with OAG staff re disclosure claim and Instagram allegationsCalls0.9Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$850.50$3,402.00
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2/8/2022AlexDravillasResearch potential claims for petitionResearch0.6Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$567.00$2,268.00
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2/8/2022AshleyKellerReview draft petitionRevising/Editing5Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$4,725.00$18,900.00
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2/8/2022AshleyKellerCall w/ OAG re: CUBI - Texas v. Meta/FB Draft petitionCalls1Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$945.00$3,780.00
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2/8/2022ZinaBashParticipate on call with OAG, McKool, and KL to discuss KL's draft petition.Calls0.8Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$756.00$3,024.00
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2/8/2022ZinaBashParticipate on call with B. Schuelke and S. Robbins from OAG and N. Larry and A. Dravillas from KL to discuss whether to include particular allegations in the petition, including certain facts that were derived from CID responses.Calls1.1Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$1,039.50$4,158.00
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2/8/2022ZinaBashResearch CID responses to decide whether and how to update the draft petition.Research2.2Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$2,079.00$8,316.00
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2/8/2022ZinaBashReview and revise draft petition to incorporate discussion with OAG and McKool.Revising/Editing4.1Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$3,874.50$15,498.00
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2/9/2022MarissaSpaldingCorrespondence to local counsel regarding PHV Motions and procedure to ensure both are correct.Email0.2Paralegals including eDiscovery Professionals$200.00$40.00$160.00
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2/9/2022NickLarryReviewing OAG emails re redacted materials in petition and filing under seal, reviewing Whalen docket for public facts re: Instagram collection, emailing Bash and Dravillas re changes to petition to avoid filing under seal, call with Bash re sameEmail0.4Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$378.00$1,512.00
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2/9/2022NickLarryReviewing OAG edits to draft petition, emailing Bash and Dravillas re same, marking up petition with further revisions and commentsEmail0.4Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$378.00$1,512.00
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2/9/2022NickLarryResearching timeline of Facebook privacy missteps and sending to Bash for inclusion in petitionResearch0.2Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$189.00$756.00
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2/9/2022AlexDravillasResearch on Facebook patents that track consumers for petitionResearch0.3Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$283.50$1,134.00
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2/9/2022ZinaBashDiscuss filing process with S. Baxter to confirm precise steps for the filing in Marshall.Meetings0.3Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$283.50$1,134.00
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2/9/2022ZinaBashDiscuss with S. Cowles of OAG the latest petition and OAG's preference for filing logistics in Marshall.Meetings0.3Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$283.50$1,134.00
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2/9/2022ZinaBashResearch and discuss whether to keep or drop a particular claim; research whether to keep allegations stemming from CID responses, including by researching filing procedures for confidential material; draft and review emails among OAG and KL re same; review draft from B. Schuelke of OAG and discuss same with N. Larry and A. Dravillas; reconcile KL draft with draft from B. Schuelke.Research4.5Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$4,252.50$17,010.00
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2/10/2022MarissaSpaldingReview and proof petition.Revising/Editing1.4Paralegals including eDiscovery Professionals$200.00$280.00$1,120.00
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2/10/2022NickLarryCall with Brian Mueller to discuss injunctive relief in petition, emailing Bash and Dravillas re sameCalls0.6Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$567.00$2,268.00
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2/10/2022NickLarryEmailing with Bash and Dravillas re need for redactions on certain allegations in petitionEmail0.3Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$283.50$1,134.00
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2/10/2022NickLarryReviewing Bash draft PR statement, emailing re sameRevising/Editing0.2Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$189.00$756.00
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2/10/2022AlexDravillasResearch re legislative history for petitionResearch0.3Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$283.50$1,134.00
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2/10/2022ZinaBashParticipate on call with S. Cowles, A. Reitz, and A. Garcia of OAG, and S. Baxter and J. Truelove of McKool, to discuss the petition and filing logistics.Calls1Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$945.00$3,780.00
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2/10/2022ZinaBashOrganize call with outside parties that will cover petition.Calls1Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$945.00$3,780.00
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2/10/2022ZinaBashDiscuss with S. Cowles, A. Garcia, and A. Keller an overview of the petition for purposes of representations to outside parties.Meetings0.5Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$472.50$1,890.00
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2/10/2022ZinaBashReview new edits by B. Schuelke; update draft; research FTC settlements; add in signature blocks for OAG attorneys; revise draft; review draft with edits from S. Robbins; discuss same with N. Larry and A. Dravillas; revise draft.Revising/Editing4.2Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$3,969.00$15,876.00
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2/11/2022NickLarryReviewing IL BIPA class action docket for discussion of Tag Suggestions roll-out in Texas, emailing Dravillas and Bash re confidentiality of same and need to redact or reframe petition. Calls with Dravillas and Bash re same.Email0.6Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$567.00$2,268.00
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2/11/2022AlexDravillasOutline/draft internal whitepaper on Facebook CUBI violationsOutlining1.9Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$1,795.50$7,182.00
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2/11/2022AlexDravillasResearch on machine learning for white paper on Facebook CUBI violationsResearch2.2Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$2,079.00$8,316.00
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2/11/2022AlexDravillasResearch re disclosure of the Texas roll out of Tag Suggestions vs roll out in other statesResearch0.6Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$567.00$2,268.00
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2/11/2022AlexDravillasCall with N. Larry re allegations in petition and FB knowledge of CUBICalls0.2Attorney - Partner, Shareholder, and/or Attorney with 9+ years of litigation experience$945.00$189.00$756.00