Case 1:11-cv LAK-JCF Document Filed 01/09/18 Page 6 of 17. j Mar-13. 3~Z7 (~, ' ~~е, DATE HOURS DESCRIPTION COST ~

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1 Case 1:11-cv LAK-JCF Document Filed 01/09/18 Page 6 of 17 ('vl4, «ѕ 7Т& j Mar-13 MAX GITTER Chevron v. Donziger 3~Z7 (~, ' ~~е, DATE HOURS DESCRIPTION COST ~ 3/26/2013 2'5 Reading order of appointment and other orders; s with Ormand, T. Katz and other(many; notes and to/do's $1, Jo Ii / 3/27/2013 3/28/2013 3/29/2013 3/30/ Lengthy conference with Ormand; conference with Ormand and altace conferences with Ormand, sos~and Rodriq ez; many s continuing review of docket; gathering documents; calf wi[iгpт ctiveparalegai; s with Katz; lengthy conference call with Katz and Ormand; call with Ormand in evening 4, Reading materials identified in docket sheet; many phone conferences and s with Ormand; conf/calls with Katz (3); draft to all counsel; additional s; reading second circuit order and calls re same; reading new Kaplan orders; more background reading 3, Work on matter starting 7 am and into evening, including: many s with Ormand; many s from all counsel; drafts of responsive s; conf/call wjth Katz and Ormand; review of old opinions and orders and other prior proceedings materials; conf/calf with Katz and Ormand; drafts of Order No. 1; etc. 4, Calls with Ormand and Katz during midmorning; drafts of Order ##2 and calls re: same at lunch hour; conference calls with Ormand and Katz in late afternoon and finalizing Order #2; reading filings on 3/29. 1, TOTAL $15,225.00

2 Case 1:11-cv LAK-JCF Document Filed 01/09/18 Page 7 of 17 J Apr-13 MAX GITTER Chevron v. Donziger DATE HOURS DESCRIPTION COST 4/1/ Early morning conferences with Ormand; conference calls (several) with Katz and Ormand; agenda for call with counsel; preparation for call with counsel and conference call; call with Ormand and Katz afterward; to do's and late night drafts of to all counsel re: schedules. $2,100:0 4/2/ and Katz disclosure from JAMS; letter to Judge Kaplan; phone conferences with Ormand in morning; phone conference with Katz; s with Ormand; drafts of to all counsel re: prior evening conference call 1, /3/ Several lengthy phone conferences with Ormand; conference call with Ormand and Katz; from counsel re: depòsitions; start reading of briefs on motion for sanctions / Morning conference call with Ormand and Katz. Update call with Court. Several calls with Ormand. Drafts of to all counsel. Evening conference call with Ormand and Katz. Review of docket. 1, /5/ Reading briefs from SDNY and 2d Cir. Filings in recent days; close review of parties' joint submission on depositions; additional s from parties re: same; lengthy phone conference with Ormand re: same; s with Katz re: same. 1, /6/ :00 AM conference call with Katz and Ormand; reading Kohn materials attached to counsel ; brief call from Judge Kaplan. 1, /8/ Breakfast meeting with Katz and Ormand (1.5 hr) lengthy meeting with Ormand in office afterward; many calls and s in afternoon re: Lima depositions; evening drafting of message to all counsel and editing and s re: same; reading new orders re: joint submission on depositions, and on Stratus dismissal; miscellaneous calls and s,with Ormand throughout the day. 3, /9/ Several conferences with Ormand in AM and s throughout the day; s with Katz; evening review of Keker/JAMS correspondence; gathering materials to prepare for depositions next week

3 Case 1:11-cv LAK-JCF Document Filed 01/09/18 Page 8 of 17 4/10/ Extensive readings of opinions, briefs, etc. to prepare for depositions next week; many s with Ormand, Katz; conference call with Katz and Ormand; many other s; reading new order re: evidentiary hearing and review of traffic re: depositions and same; calls all day with Ormand. 4, /11/ hr Call with Judge Kaplan; several calls with Ormand; reading new orders in circuit and district court; s with Ormand; from counsel; drafting order re: depositions; with Katz.. 1, /12/ Early AM conference call with Katz and Ormand; reading parts of lengthy new filings; calls and s with Ormand re sàme; s re: Lima; from counsel re: Denver depositions and consideration of same; s with Ormand re: same. 2, /14/ Reading opinion re: Kohn and Garr; phone conference with Ormand re.: same; additional reading from new materials on docket. 1, /15/ Reading Judge Francis opinion; s with Ormand Lengthy AM meeting with Ormand re: outstanding issues and matters; 4/16/ /17/ /18/ /20/ /22/ miscellaneous Reading hearing transcript; s with Ormand and Katz re: deposition scheduling;; draft to ail counsel; evening s and lengthy phone conference with Ormand Long meeting with Ormand in AM; work on to counsel; reading transcript 1, Long conference call with Ormand and Katz (1 hr); reading. s to and. from counsel; reading attachments 1, Work on letter to Judge Kaplan in morning; many many s with Ormand and Katz; several phone conferences with Ormand; work on Special Masters Order no. 3; s and calls re same; considering ideas re: scheduling and drafts re same; review of Chevron motion for protective order; very lengthy evening conference call with Ormand and Katz re same; review of new docket entries 3,500.00

4 Case 1:11-cv LAK-JCF Document Filed 01/09/18 Page 9 of 17 4/23/ /24/ /25/ /26/ /28/ Calls with Judge Kaplan; meeting in office with Ormand; many, many s with Ormand all day; work on drãft communication with all counsel re: Beier; s with Katz and Ormand re: same and other matters; supp. Memo from Newman re: Rivero dispute; s from Gibson and Veleska; s from Gomez; new orders on docket; letters from Keker et al to Katz; materials from Gibson re: Beier; conference call with Katz and Ormand; evening s and work. 4, Early morning s with Ormand and; Katz re: Rivero; calls with same during deposition breaks; lengthy conference call with counsel after Rivero deposition re: scheduling; s from Haddon firm; start reading memos and exhibits from Gibson and Haddon re: Beier deposition. 1, Work from 6:00 AM and virtually all day thereafter on matter, principally preparing for depositions and trying to arrange schedule, including: reading Rivero transcript and phone conferences with Katz and Ormand re: same; close reading of submissions by Chevrón and Haddon re: Beier; requests for additional information from counsel re: same and review of same; phone conference with Judge Kaplan; review of new docket entities in main action and in 1782 action; many, many s and phone conferences with Ormand; consideration of privilege and other issues re: Beier; long phone conference with Ormand at about 6:00 PM, etc. 5, Collecting materials from Docket re: Beier, Shinder and McDermott; many s with Ormand and Katz; various communications with all counsel; legal memo from Irrand; reading cases from SDNY and Colo; lengthy meeting with Ormand at 5:00 PM. 2, Letter from Mastro re: Smyser/Keker s; outlining work plan for preparation for Beier related fites; evening phone conference with Ormand 2,450.00

5 Case 1:11-cv LAK-JCF Document Filed 01/09/18 Page 10 of 17 4/29/ /30/ Start work at 6:30 AM; from Weitzman with enclosures; continued drafts of two memos/orders; conferences with Ormand; conference calls with Katz and Ormand; setting up conference call with all counsel re: changes in Lima schedule; conference call with all counsel re: same and re: other matters; conference call with Katz and Ormand afterwards; s to Beier counsel; evening s from Beier counsel and Gomez; many s and phone conferences with Ormand through late evening re: same and discussions re: in camera documents received from Beier counsel. 4, Start work at 4:30 am; start reading documents delivered late yesterday from counsel for S&D; s overnight; meeting with Ormand starting 7:30 am to review documents in camera for privilege rulings; travel to deposition room and further reviews; work with Ormand on draft orders; deposition all day of Beier till well into evening; travel home and consideration of issues raised during deposition and consideration of order to follow. 9, TOTAL 85 $59,500.00

6 J_ D Case 1:11-cv LAK-JCF Document Filed 01/09/18 Page 11 of 17 May-13 MAX GITTER Chevron v. Donziger DATE HOURS DESCRIPTION COST Early AM calls with Ormand, Judge Kapian's chambers; s with Katz re: various matters; work on draft order re: Zambrano; emaiis from Newman re: dep. Schedule and my s to Katz and Ormand re: same; extensjve work on opinion and order re: common jnterest through various drafts s and 5/1/ calls with Ormand into late evening. $2, Further drafts of order on common interest in very early AM; s and conference with Ormand; travel to deposition and supervising deposition ali 5/2/ day. 9, Many, many s and calls all day with Ormand and Katz dealing with deposition schedule; drafting s to all counsel; receipt of letters from Mastro and Smyser; communications with Judge Kaplan's chambers re: new filings by various parties; reading motions to withdraw by Keker and Smysеr; 5/3/ reading motion by Chevron for deposition of Tyreii, etc. 3, Work nearly all day on various matters; several drafts of Order No. 7; many s, docket updates, phone conferences with Ormand and Katz; 5/6/ reviewing other documents, etc. 3, Start work at 8 am; voice mails with Ormand; meeting with Ormand in office; s and conference call with Ormand and Katz; draft order; draft re third party attorney's; s from counsel re continuation of Guerra 5/7/ deposition; drafts of order No. 8; other s; etc 2, s re Woods deposition from early am and throughout day; new entries on docket; s and conference with Judge Kaplan; conference call with 5/8/ Katz and Ormand; many other s and calls 3, s with Katz and Ormand starting at 7:45; conference call with same; drafts of and s to all counsel re Woods (many) ; letter from Smyser; 5/9/ drafts of order no. 9 (not finalized); work into late evening 3,325.00

7 Case 1:11-cv LAK-JCF Document Filed 01/09/18 Page 12 of 17 5/10/ /11/ /12/ /13/ /14/ /15/ /16/ Many early am s with Ormand and Katz; calls and s throughout day re Woods Callejas deposition; call withjudge Kaplan; to all counsel re Woods dep; conference call with Ormand and Katz in evening rе Callejas deposition 2, Reading materials filed on docket (brief and affidavit + some exhibits re withdrawal of counsel); letter from Mastro re Watson & Scott Start extensive preparation for Woods deposition, reading orders, cases, etc.; meetings with Barras in office (2); s and calls with Ormand in Lima; letter from Keker; s from Weitzman; other s; late night s re Zambrano; organizing materials re Woods deposition. 4, Work all day starting early am: review of new docket entries throughout day; several conferences and phone conferences with Barras in office; s and phone conferences with Barras; s and phone conferences wjth Ormand; conference/call with Katz and Ormand in Peru; review of new brief and exhibits from Chevron re Woods; reviewing transcripts, cases, recent orders, etc. re Woods and outlining points; organizing parts of 1782 transcripts relevant to Woods; additional s and calls into evening and other work well into evening. 5, Continued prep for Woods deposition in early am; s with Ormand; supervising Woods deposition including travel to and from Gibson offices; s in late evening; phone conference with Ormand in late evening. 4, Early AM s and drafts of orders, etc.; s with Ormand and Katz in am; lengthy conference call with Ormand and Katz in AM; reviewing and revising draft s and orders to counsel from Ormand; call with Judge Kaplan; s throughout day; letters from counsel in early evening. 3, Early AM call with Ormand; conference call with him and Katz; work on Order 10 and possible additional message to counsel; call with chambers; review of new Judge Kaplan orders and additional docket entries; calls with Ormand and Katz re: same; s from counsel; finalizing Order 10. 2,450.00

8 Case 1:11-cv LAK-JCF Document Filed 01/09/18 Page 13 of 17 5/17/ /20/ /21/ /22/ /23/ Start work early AM planning for call among counsel re: schedule; to all counsel re: Kohn/Garr documents and responses; s in afternoon from Gibson re: schedule, with full attachments; from Donziger; conference call with Ormand and Katz; long conference call with all counsel on record re: scheduling; call and s with Ormand afterward. 2, Work all day starting at 8 AM and going late into evening relating to deposition scheduling, including lengthy conference call with all counsel, many, many s with all counsel, exchanges of draft proposals, consideration and creation of additional proposals not offered by counsel, many, many calls and s with Ormand; tracking down flights for Mr. Gomez, counsel for individual defendants.; start preparation for McDermott deposition; s etc. re Garr/Kohn documents and stipulation re same; review of docket and new docket entries; phone conference with Judge Kaplan's chambers;, drafting instructions to counsel, etc. 5, Deposition of McDermott, including travel to and from Gibson; call with Judge Kaplan; review of new order; s with Donziger, et al; from Keker in evening; conference call with Katz; correspondence with Gomez,. Mastro, Gray, and others. 5, Work from 8:00 AM to 10:30 PM with breaks only for lunch and dinner, including: meeting with Ormand in early AM; reading conference call transcripts and making corrections; retrieving and printing history over last week and reviewing in preparation for report to court; from Donzinger; s from other counsel; start work on draft report to court; many drafts of report to court all day and into evening; many s with Ormand and Katz all day and well into evening; brief from Mastro in evening; calls with Ormand all day and into evening; final revisions of draft report to court at night, etc. 6, Finalizing interim report 2; call with chambers; s and calls with Ormand; travel to and from court and attendance at hearing re Donziger motion; s with counsel; new order from Judge Kaplan in evening and long conference with Ormand re same; etc 3,500.00

9 Case 1:11-cv LAK-JCF Document Filed 01/09/18 Page 14 of 17 5/24/ Start work early AM on draft order for hiatus in depositions; phone conference with ormand and Katz; from Gomez; from Mastro; drafts of new order re: depositions next week; phone conferences with Ormand and Katz re: same; calls in evening. 1, /25/ Long from Donziger and calls re: same; s from Weitzman. et al; several AM phone conferences with Ormand; also with Katz; work on Order No. 12; many, many s with Ormand including well into evening; additional from counsel in evening.. 3, Start work at 7:00 AM outlining arguments re: Woods' privilege assertions; early AM s with Katz and Ormand; long conference call with Katz and Ormand at 8:30 AM; draft s to counsel; review of 2d cir. Brief filed Thursday and Tuesday; long call with Ormand in evening and review of parts 5/28/ of testimony. 2, Start work at 5:00 AM, including read Weitzman and attachments received late last night; drafting responses; s to Ormand and Katz by 7:00 AM; start preparing for meeting with all counsel; lengthy morning meeting with Ormand; s with Katz re: upcoming meeting. 3-hour meeting with all counsel; lunch conference afterward with Ormand and Katz; s all afternoon re: follow up; many drafts of Order 13; s from. 5/29/ Gomez, Weitzman; draft responses; many evening with Ormand and Katz; work until 8:00 PM. 6, Organizing documents from Wednesday conference; consideration of new requests to counsel and long memo to Katz and ormand re: same; s 5/30/ with Katz and Ormand throughout day and into early evening 1, Start work at 6:00 AM; late night from Weitzman; early AM s with Katz and Ormand; markup of Ormand draft of requests to counsel; long memo on Wood's privilege assertion; questions for Ormand re: old transcript; conference call at noon with Katz and Ormand and preparation for same; from Weitzman late afternoon re: schedule; late night 5/31/ exchanges of with Ormand 2, $93, TOTAL

10 Case 1:11-cv LAK-JCF Document Filed 01/09/18 Page 15 of 17 Jun-13 MAX GITTER Chevron v. Donziger DATE HOURS DESCRIPTION COST s from Donziger; drafts of order No. 14; s re: new stipulations and orders in afternoon; report from Weitzman re: Garr/Kohn 6/3/ documents; later evening s with Ormand. $ /4/ Reading opinions, orders in preparation for Garr deposition; outlining rulings on possible objections; long conference with Ormand re same; many s; evening review of documents produced by Garr 2, /5/ Garr deposition 7, /6/ Deposition of Kohn (including, travel and post deposition argument); long conference with Ormand afterward; s in evening re late afternoon ruling 8, /7/ Work most of the day on variety of topics, including: follow up to ruling at Kohn deposition; new requests by Gomez re: Kroll deposition; additional submissions re: request to extend time on 30b6 depositions; submissions by Chevron (2) and Donziger re: Woods privilege assertions; updates to Katz and Kaplan; preparing for Kroll deposition; consideration of law of the case; research re: various issues; many, many s and calls re: all of the above. 3, /8/ Early AM from Mastro re: Kroll; several more s from counsel re: Kroll; two conference calls with Katz and Ormand; work on orders 15 and 16; s and calls with Ormand; long from Donziger re: Kroll; new request from Gibson Dunn re: Tyrell; drafts of responses re: Tyrell; final of Order 15, etc. 2, /9/ Reading materials in preparation for Kroll deposition; drafts and edits of Order 16; s and phone conferences with Ormand. 1, /10/ Preparation for and attendance at the Kroll deposition 9,100.00

11 Case 1:11-cv LAK-JCF Document Filed 01/09/18 Page 16 of 17 6(11/ /12/ /13/ /14/ /15/ /16/ /17/ /18/ /19/ /20/ /21/ /23/2013 б.75 6/24/ /25/ Many s with Ormand; finalizing Order 16; call with` chambers; conference with Ormand; phone calls with Ormand in afternoon and evening; start reading materials for Tyrell deposition; consideration of procedures of Woods deposition; new docket entries; etc. Preparation for Tyrell deposition; calls with Katz and Ormand; many s with Ormand; reviewing materials re: woods; etc. Deposition of Tyreli, including travel and long conference with Ormand afterward Lengthy conference call with Katz and Ormand; s. Sevеral calls and еmails with Ormand preparing for mediation; review of Woods materials to prepare for mediation; very long conference calls in mediation. s and calls re: resumption of mediation; mediation conference call. Lunch conference with Ormand and Katz (including travel); s from Ormand, Gross, et al. Deposition of Woods, including travel and post depisition conference with Ormand Various phone calls and s re Gomez and Donziger appeals from rulings at Kroll and Kohn depositions; phone confs and s to obtain materials re deposition of Zygocki; start preparation for Zygocki deposition; evening s from Gomez and Ormand At office and preparing for Zygocki deposition; work on to counsel re completeness; s and calls with Ormand and Katz on various issues Deposition of Zygocki, including travel and meeting with Ormand afterward Long phone conference with Ormand; s from Weitzman and Ormand. Conference call with Katz and Ormand; new order on docket Two conference calls with Katz and Ormand from Donziger deposition; lengthy late night call with Ormand 2, , , , , , , ,

12 Case 1:11-cv LAK-JCF Document Filed 01/09/18 Page 17 of 17 6/26/2013 6/27/2013 6/28/ Long meeting with Ormand in morning; several rulings on phone in course of Dunkelberger deposition; lengthy portion of Dunkelberger deposition attended by phone and additional rulings made; exchange with chambers re deposition schedule; several additional phone conferences with Ormand; s from Weitzman, Gomez (several), others Work on new order and new interim report much of day; many s and calls; call with chambers late in day Reading of three new orders and draft of Friday's transcripts. 2, , $ 78,050.00