GUTRIDESAFIERREESELLP MichaelR. Reese(Cal. State BarNo....
Transcript of GUTRIDESAFIERREESELLP MichaelR. Reese(Cal. State BarNo....
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GUTRIDE SAFIER REESE LLPMichael R. Reese (Cal. State Bar No. 206773)Kim E. Richman (admitted pro hac vice)230 Park Avenue, Suite 963New York, New York 10169Telephone: (212) 579-4625Facsimile: (212) 253-4272
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GUTRIDE SAFIER REESE LLPAdam J. Gutride (Cal. State Bar No.181466)Seth A. Safier (Cal. State Bar No. 197427)835 Douglass StreetSan Francisco, California 94114Telephone: (415) 271-6469Facsimile: (415) 449-6469
Court Appointed Lead Counsel
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION
RONALD SIEMERS and FORRESTMCKENNA, Individually And On Behalf Of AllOthers Similarly Situated,
Plaintiff,
vs.
WELLS FARGO & COMPANY, WELLSFARGO INVESTMENTS, LLC, WELLS FARGOFUNDS MANAGEMENT, LLC, WELLSCAPITAL MANAGEMENT INC., STEPHENSINC., WELLS FARGO FUNDS DISTRIBUTOR,LLC, and WELLS FARGO FUNDS TRUST,
Defendants.
Case No. 05-04518 WHA
DECLARATION OF ADAM J.GUTRIDE IN SUPPORT OFPLAINTIFF'S MOTION FOR AWARDOF ATTORNEYS' FEES ANDEXPENSES
DATE: JANUARY 31, 2008TIME: 8:00 AMCTRM: 9, 19TH FLOORJUDGE: JUDGE WILLIAM H. ALSUP
Declaration of Adam J. Gutride Re Plaintiff s Motion for Award of Attorneys' Fees and Expenses
Case No.: 05-cv-04518 (WHA)
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I, Adam J. Gutride, do hereby declare the following:
1. I am a member of the Bar of this Court and a partner in the firm of Gutride Safier
Reese LLP, Court-appointed class counsel. I make this declaration of my own personal knowledge.
2. I have reviewed the timesheets prepared by the attorneys and legal assistants
employed by my firm in connection with this case . Attached hereto as Exhibits A through D are
charts showing the hours worked those persons on this case . Exhibit A shows totals by timekeeper,
their hourly rates and total lodestar . Exhibit B shows details with respect to work performed on
each court filing. Exhibit C shows details with respect to work performed in discovery. Exhibit D
shows details with respect to other work performed.
3. I have reviewed the expenses incurred by this firm to prosecute this case. Attached
hereto as Exhibit E is a chart of those expenses. Included in the chart are travel expenses that this
firm advanced for the lead plaintiffs to come to San Francisco for hearings and deposition.
4. The charts attached hereto do not include the additional hours Class Counsel will
spend preparing for and attending the final approval hearing, addressing shareholder opt-outs and
objections, and consulting with the claims administrator to facilitate settlement administration. I
anticipate that this work will take an additional 30 to 50 hours, assuming there are no appeals from
the judgment.
I declare under penalty of perjury under the laws of the United States that the foregoing is
true and correct. Executed this 21st of December, 2007 in San Francisco, California.
/s/ Adam J. GutrideADAM J. GUTRIDE
Declaration of Adam J. Gutride Re Plaintiff s Motion for Award of Attorneys' Fees and Expenses 2
Case No.: 05-cv-04518 (WHA)
EXHIBIT A
Summary of all hours-Gutride Safier Reese LLP
TIMEKEEPER TOTAL HOURS RATE TOTALAJG 762.25 $475.00 $362,068.75MRR 852.25 $525.00 $447,431.25SAS 493.25 $450.00 $221,962.50KER 85.5 $325.00 $27,787.50KJS 15.75 $375.00 $5,906.25JPM 113.75 $375.00 $42,656.25EJM 208.5 $375.00 $78,187.50
TOTAL 2531 .25 $1,186,000.00
EXHIBIT B
Pleadings, Hearings
Draft, Edit Class Action Complaint
Summonses
Review ADR Scheduling Order, Supplemental OrderTo Order Setting Initial Case ManagementConference; Standing Order For Early Notice To ClassMembers In Federal Securities Cases; Clerk's NoticeRe: Failure To E-File And/Or Failure To Register AsAn E-Filer; Notice Of Appearance By Bruce A.Ericson
Review, Edit Stipulation And [Proposed] SchedulingOrder; Order Approving Same
Draft, Confer With Client Regarding Motion ToAppoint Lead Plaintiff And Lead Counsel Filed ByThe McDaniel Family Trust; Proposed Order ReSame; Declaration Of Seth A. Safier In Support
Review, Edit Stipulation And [Proposed] Order ToContinue Case Management Conference And RelatedDates)
Date TimekeeperFiled orComp-leted AJG MIRR SAS KER KJS JPM EJM
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Date Timekeeper
Pleadings, Hearings Filed orComp-leted AJG MRR SAS KER KJS JPM EJM
Review Motion For Leave To Appear In Pro Hac Vice, 01/27/06Janine L. Pollack, Esq., Steven G. Schulman, Esq.,Jerome Congres
Review Order Denying Stipulation To Cancel Case 01/30/06 .25Management Conference
Review Statement Of Non-Opposition Re: Motion For 02/02/06 .25Appointment Of Lead Plaintiff And Lead Counsel
Review Joint Case Management Statement, Rule 02/02/06 .2526(F) Report And [Proposed] Order Filed ByDefendants
Draft, Edit Certificate Of Counsel By Seth A. Safier 02/06/06On Behalf Of The McDaniel Family Trust
Draft, Edit Certificate Of Counsel Adam Gutride By 02/06/06 .25Seth A. Safier On Behalf Of The McDaniel FamilyTrust
Review Certificates Of Other Counsel 02/06/06 .25
Review Scheduling Order. 02/09/06 .25
Prepare For, Attend Initial Case Management 02/09/06Conference
Review Order Re Lead-Plaintiff Questionnaire. 02/10/06 .25
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Pleadings, Hearings
Review Clerk's Notice Rescheduling Motion Hearing.
File Summons Returned Executed By The McDanielFamily Trust.
Review, Confer With Client Re Motion To AppointLead Plaintiff And Lead Counsel Revised Notice OfMotion To Appoint Ronald Siemers As Lead Plaintiff,Approval Of Lead Plaintiffs Selection Of LeadCounsel, And Memorandum Of Points AndAuthorities In Support Thereof, SupportingDeclaration Of Reese
Review Defendants' Response To Court's QuestionsRe: Appointment Of Lead Plaintiff And Lead Counsel
Review Corrected Revised Notice Of Motion ToAppoint Ronald Siemers As Lead Plaintiff, ApprovalOf Lead Plaintiffs Selection Of Lead Counsel, AndMemorandum Of Points And Authorities In SupportThereof And Declaration
Review Minute Entry Re Motion To Appoint LeadPlaintiff And Lead Counsel
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Date Timekeeper
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Review Order By Judge Alsup Granting In Part And 02/28/06 .25 .5Denying In Part Motion To Appoint Lead PlaintiffAnd Lead Counsel
Review Order Correcting Lead-Plaintiff Deadlines 03/01/06 .25
Review Affidavit Certification Of Lead Plaintiff 03/08/06 .25Ronald Siemers By The McDaniel Family Trust.
Review Declaration Of Court Appointed Lead Plaintiff 03/09/06 .25 .25Ronald Siemers Re: Choice Of Lead Counsel Filed ByRonald Siemers . Filed Under Seal
Review Order Approving Selection Of Class Counsel.. 03/14/06 .25 .25
Pleadings, Hearings
Review Filings During Time That Milberg Weiss WasLead Counsel (Dockets 59-97), Including:• Amended Complaint• Summons To Wells Fargo Funds Distributor• Letter From Bruce Ericson, 4/24/06• Letter From Lead Counsel Re Lifting Discovery
Stay, 4/24/06• Defendant's Motions To Dismiss And Motion To
Strike, Requests For Judicial Notice, Exhibits• Defendants' Opposition To Motion To Compel• Transcript Of Discovery Hearing• Plaintiff's Opposition To Motions To Dismiss And
Strike, Declarations Of Siemers And Reese InSupport, Request For Judicial Notice
• Plaintiffs' Motion To Strike• Defendants' Opposition To Plaintiffs' Motion To
Strike• Defendants' Replies In Support Of Motions To
Dismiss And Strike• Transcript Of Proceedings Held On 02/23/06
Review Order Re Lead Counsel.
Review Response and Declaration Of Michael R.Reese To June 8, 2006 Court Order Re Lead Counsel
Date TimekeeperFiled orComp-leted AJG MIRR SAS KER KJS JPM EJM
04/11/06 4.5 5
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Pleadings, Hearings Filed orComp-leted AJG MRR SAS KER KJS JPM EJM
Review Order For Further Briefing On Defendants' 06/13/06 .25 .25Motion To Strike. Signed By Judge Alsup On 6/13/06.
Review Plaintiffs Brief In Response To The Court's 06/15/06 .25 .25June 13, 2006 Order For Further Briefing On TheTimeliness Of Defendants' Motion To Strike ByRonald Siemers.
Review Brief (Supplemental) In Support Of 06/15/06 .25 .25Defendants' Motion To Strike References To ConsentDecrees In Plaintiffs Consolidated Amended ClassAction Complaint Filed By All Defendants.(Filed On6/15/2006) Modified On 6/19/2006
Review Statement Of Recent Decision Pursuant To 06/16/06 .25 .25Civil Local Rule 7-3.D Filed By All Defendants.
Review Order Requesting Comment For June 21 06/20/06 .25 .25Hearing.
Review Response To Order Requesting Comment By 06/21/06 .25 .25All Defendants.
Draft, Edit Plaintiffs Response To June 20, 2006 Court 06/21/06 .75 2Order Requesting Comment By Ronald Siemers.
Attend Motion Hearing Held On 6/21/2006 Re 06/21/06 2 2Motions To Dismiss, Strike
Date Timekeeper
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Review ORDER. 06/26/06 .25 .251 1 1 1
Participate In ADR Phone Conference 06/26/06 .25
Draft, Edit Ex Parte Declaration Of Michael Reese In 06/29/06 1Response To June 26 Court Order To Counsel MichaelReese (Redacted) By Ronald Siemers.
Review Order Approving Change Of Lead Counsel. 06/30/06 .25 .25 .25Signed By Judge Alsup On 6/30/06.
Participate In ADR Phone Conference 08/08/06 .25
Review Order Granting In Part And Denying In Part 08/14/06 .5 .5 .5 .5Motions To Dismiss, Strike
Draft, Edit, Confer With Client Re Second Amended 08/31/06 2.5 33.5 1 .75Complaint
Participate In ADR Phone Conference 09/06/06 .75
Review Clerk's Notice Scheduling Case Management 09/11/06 .25 .25Conference
Draft, Edit [Proposed] Order Re Request For 09/14/06 .5Continuance Of Case Management Conference
Pleadings, Hearings
Review Defendants' Motion To Dismiss Plaintiff sSecond Amended Consolidated Class ActionComplaint, Request For Judicial Notice, ProposedOrder
Date TimekeeperFiled orComp-leted AJG MIRR SAS KER KJS JPM EJM
Review Stipulation And Order Continuing Case 0Management Conference And Related Dates.
Review Defendants' Amended Motion To Dismiss 0Plaintiffs' Second Amended Consolidated Class ActionComplaint, Errata Re Same
Review Joint Case Management Statement Filed By 0All Defendants.
Review Case Management Scheduling Order: Order 0Referring Case To Magistrate Judge Elizabeth D.Laporte For Mediation/Settlement. Order Lifting Stay.
Draft, Edit Memorandum In Opposition Re Motion To 0Dismiss Plaintiffs Second Amended ConsolidatedClass Action Complaint, Declaration Of MichaelReese, Request For Judicial Notice
Prepare For, Attend Initial Case Management 0Conference (includes travel from NYC to SF forMRR)
09/14/06 2. 0 3. 0 . 50
Date Timekeeper
Pleadings, Hearings Filed orComp-leted AJG MRR SAS KER KJS JPM EJM
Review Order Rescinding Reference And Making New 10/02/06 25Order Of Reference To Magistrate Judge Spero ForMediation/Settlement.
Review Transcript Of Proceedings Held On 06/21/06 1
Review Order Reassigning Case. To Judge Joseph C. 1Spero For All Further Proceedings.
Participate In Telephone Conference To Discuss 10/04/06Possible Dates For Settlement Conference.
Review Defendants' Reply In Support Of Motion To 1Dismiss Plaintiffs' Second Amended ConsolidatedClass Action Complaint
Draft, Edit Letter From Lead Counsel For Plaintiff 1Regarding Proposed Case Management Order No. 2Modifying Deadline For Seeking Leave To AddParties Or Claims.
Review Notice Of Settlement Conference And 1Settlement Conference Order.
Review Notice Re October 19, 2006 Argument. 1
Review Notice Of Substitution Of Counsel By Patricia 1J. Medina
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Date Timekeeper
Pleadings, Hearings Filed orComp-leted AJG MRR SAS KER KJS JPM EJM
Draft, Edit Stipulation And [Proposed] Order Re Initial 10/17/06 .5Disclosures (Fed.R.Civ.P.26(A)(1))
Review Order Approving Stipulation And Order Re 10/19/06 .25Initial Disclosures
Prepare For, Attend Motion Hearing On 10/19/2006 10/19/06 3.5 26 4Before William Alsup Re Motion To DismissPlaintiffs Second Amended Consolidated Class ActionComplaint, (includes travel from NYC to SF for MRR)
Review Order Granting In Part And Denying In Part 10/24/06 .5 .5 .5 .5Motion To Dismiss
Draft, Edit Stipulation And [Proposed] Order To 10/25/06 .25 .25Modify Briefing Schedule On Motion For ClassCertification By Ronald Siemers.
Review Order Approving Stipulation And Order To 10/26/06 .25 .25 .25Modify Briefing Schedule On Motion For ClassCertification
Draft, Edit Motion For Leave To Appear In Pro Hac 10/26/06 1 .25 .75Vice, Kim E. Richman, Esq.,
Review Order By Judge William Alsup Granting 10/31/06 .25Motion For Pro Hac Vice Of Kim E. Richman.
Pleadings, Hearings
Edit Stipulation Extending Time For InterrogatoryResponses And Objections By Wells Fargo &Company, Broker-Dealer Defendants.
Edit Stipulation Extending Time For Responses ToRequests For Production By Wells Fargo & Company,Broker-Dealer Defendants.
Draft, Edit First Motion To Amend/Correct SecondAmended Complaint Filed By Ronald Siemers,Declaration Of Michael Reese.
Review Order Re Letter OfNovember 27, 2006.
Review Scheduling Order Regarding Any Motion ToRecuse Or To Disqualify Judge.
Review Fund Defendants' Memorandum InOpposition To Plaintiffs' Motion For Leave To FileThird Amended Complaint
Review Unopposed Administrative Motion OfDefendants To File Document Under Seal; AndSupporting Declaration, Proposed Order
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Opposition To Plaintiffs Motion For Leave To FileThird Amended Complaint, Declaration Of CaseyGriffin, Jacqueline Chan, Linsey Stuckey, ProposedOrder
Review Transcript Of Proceedings Held On 10/19/06 1
Draft/Edit Reply To Opposition Re First Motion To 1Amend/Correct Second Amended Complaint,Declarations Of Joyce Kulasxa, Guinn Eiland, AlanRobbins
Draft, Edit, Negotiate Proposed Stipulated Protective 1Order No. 1
Review Clerk's Notice Continuing Motion Hearing 1
Review Order Approving Stipulated Protective Order 1Subject To Stated Conditions
Review Request Re Wells Fargo Funds. Signed By 1Judge Alsup.
Draft/Edit Declaration OfAdam Gutride In Support Of 1First Motion To Amend/Correct Second AmendedComplaint
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Pleadings, Hearings Filed orComp-leted AJG MRR SAS KER KJS JPM EJM
Prepare For, Attend Motion Hearing Re Motion To 01/04/07 4.5Amend/Correct Second Amended Complaint (includestravel time from NYC to SF for MRR)
Review Request For Further Briefing. 01/09/07 .25
Review Defendants' Response To Request For Further 01/16/07 .5Briefing
Draft, Edit Response To Order Requesting Further 01/16/07 7.5Briefing (Full And Redacted Versions), Declaration OfAdam Gutride In Support (Full And RedactedVersions), Motion To Seal
Review Request For Further Briefing 0 1/17/07 .25
Review Order Granting Motion To File Documents 0 1/17/07Under Seal
Review Declaration Of Bruce A. Ericson In Support 0 1/22/07Of Defendants' Response To January 17, 2007 RequestFor Further Briefing
Review Declaration Of Patricia J. Medina In Support 0 1/22/07Of Defendants' Response To January 17, 2007 RequestFor Further Briefing
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Review Response Of Joint Defendants To January 17, 01/22/07 .5 .5 .52007 Request For Further Briefing
Draft, Edit Brief Re Order For Further Briefing Filed 01/22/07 14 36 25By (Full And Redacted Versions), Declaration OfSeth Safier In Support (Full And Redacted Versions),Motion To Seal, Proposed Order
Draft, Edit Letter Re Discovery Dispute 01/23/07 2.5 .25
Review Order Continuing Hearing On Discovery 01/23/07 .25 .25Dispute.
Review Letter From Patricia J. Medina To Honorable 01/23/07 .25 .25William H. Alsup Re Discovery Dispute
Review Order By Judge Alsup Granting Motion To 01/23/07 .25Seal
Review Third Request For Further Briefing. 01/25/07 .25 .25 .25
Draft, Edit Stipulation Re Order Stipulation Re: Class 01/29/07 .5 .25Certification Schedule;
Review Order Re Class Certification Schedule 01/30/07 .25 I .25
Review Declaration Of Gilbert R. Serota In Support Of 01/30/07 .25 .25 .5Defendants' Response To January 25, 2007 RequestFor Further Briefing
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Review Defendants' Response To Court's Third 01/30/07 .25 .25 .25Request For Further Briefing.
Draft, Edit Response To Third Request For Further 01/30/07 5.5 7.5 18Briefing
Review Erratum Re: Defendants' Response To Court's 02/02/07 .25 .25Third Request For Further Briefing
Review Order Continuing Discovery Dispute Hearing 02/09/07 .25
Review Fourth Request For Supplemental Briefing. 02/15/07 .25 .25 .25
Review, Edit Stipulation And [Proposed] Order Re 02/15/07 .5 .25Extension Of Time To Respond To Fourth Request ForFurther Briefing
Review Order Granting In Part Stipulated Request For 02/16/07 .25Extension Of Time
Draft, Edit Response To Fourth Request For 02/21/07 8.5 13 5.5Supplemental Briefing
Review Defendants' Response To Court's Fourth 02/21/07 1 1 .5Request For Further Briefing
Review Order To Clarify Submission. 02/22/07 .25 .25 .25
Review Notice Of Impending Order To Show Cause. 02/22/07 .25 .25 .25
Date
Pleadings, Hearings Filed orComp-leted AJG
Draft, Edit Response To Order To Clarify Submission 02/22/07 4
Review Defendants' Response To Court's Fourth 02/23/07 .5Request For Further Briefing
Draft, Edit Response To Re Fourth Request For 02/23/07 6.5Further Briefing, Questions 5-6
Review Order Granting Plaintiffs' Motion To Compel 02/26/07 .25Discovery And Vacating Hearing.
Review Order To Show Cause Why Tentative Order 02/26/07 1Should Not Be Made Final.
Review Fund Defendants' Response To Tentative 03/05/07 .5Ruling
Draft, Edit Response To Order To Show Cause 03/05/07 18
Review Order Re Reply Briefs 03/05/07 .25
Review Request Signed By Judge William Alsup 03/06/07 .25
Draft/Edit Reply Memorandum To Order to Show 03/07/07 9.5Cause Why Tentative Order Should Not Be Adopted
Review Defendants' Reply To Plaintiffs Response To 03/07/07 .5Order To Show Cause Why Tentative Order ShouldNot Be Made Final
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Review Order Identifying Claims To Proceed And 03/09/07 .5 . 5 . 5Dismissing All Other Claims And Granting Motion ToAmend In Part
Review Notice Re Class Certification Issues . 03/12/07 .25 .25 .25
Review Transcript Of Proceedings Held On 01/04/07 03/15/07 .25
Draft, Edit, Confer With Clients Re Third Amended 03/21/07 36 35 4.25Complaint (Redacted And Full Versions), Motion ToSeal
Review Order Granting Motion To Seal 03/22/07 .25
Draft Mediation Statement 03/25/07 4.5 15.75
Review Motion To Dismiss Count IV Of Plaintiffs' 03/28/07 1 1.25 1Third Amended Complaint
Draft, Edit Letter From Adam Gutride To Compel 04/02/07 3.5 .25 .25Interrogatory Answers By Wells Fargo Investments(Redacted And Full Versions), Motion To Seal
Review Order Granting Plaintiffs Motion To Seal 04/02/07 .25
Review Order Setting Hearing Re Plaintiffs Discovery 04/03/07 .25Dispute
Review Defendants' Letter Re Discovery Dispute 04/04/07 .25
Date Timekeeper
Pleadings, Hearings Filed orComp-leted AJG MRR SAS KER KJS JPM EJM
Draft, Edit Memorandum In Opposition Re Motion To 04/04/07 8 . 5Dismiss Count Iv Of Plaintiffs' Third AmendedComplaint (Redacted And Full Versions), Motion ToSeal
Review Order Granting Motion To Seal 04/05/07
Prepare For, Attend Discovery Hearing 04/05/07
Review Request For Proposed Form Of Order. 04/06/07
Review Reply Memorandum Re Motion To Dismiss 04/06/07Count IV Of Plaintiffs' Third Amended Complaint
Draft Proposed Order Re Letter Granting Plaintiffs 04/06/07Motion To Compel Responses To Interrogatories ByWells Fargo Investments
Review Order Granting Plaintiffs Motion To Compel 04/09/07Responses To Interrogatories By Wells FargoInvestments.
Review Request For Information. Signed By Judge 04/10/07Alsup
Review Response Of Defendants Wells Fargo & 04/11/07Company And Wells Fargo Investments, To TheCourt's Request For Information
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RPvipw RPennneP Tn ThP Cnrnrt'Q RPniiPQt Fnr (14/1 1/(17 95
Information By Wells Fargo Fund Management, ,Wells Fargo Funds Trust.
Review Answers Of Defendants To Plaintiffs' Third CAmended Consolidated
Review Motion For Judgment On The Pleadings Filed CBy Funds Defendants, Wells Fargo Investments,Declaration Of Amy Marth, Request For JudicialNotice, Proposed Order
Review Order Denying Motion To Dismiss Third CAmended Complaint
Prepare For, Attend, Draft Statement Re Settlement CConference
Draft, Edit Notice By Ronald Siemers Of Change Of CLaw Firm Name
Review Notice And Order Setting Further Settlement CConference
Draft, Edit Motion To Certify Class Filed By Ronald CSiemers (Full And Redacted Versions); Declaration OfSeth Safier (Full And Redacted Versions), Motion ToSeal
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Pleadings, Hearings
Review Order Granting Motion To Seal
Draft, Edit, Confer With Client Re Memorandum InOpposition To Motion For Judgment On ThePleadings; Declaration Of Adam Gutride
Review Memorandum In Opposition To Plaintiffs'Motion For Class Certification Filed By FundsDefendants, Declaration Of Jason Skaggs, AndrewOwen
Review Reply Memorandum In Support OfDefendants' Motion For Judgment On The Pleadings
Review Broker-Dealer Defendants' Memorandum InOpposition To Plaintiffs' Motion For ClassCertification, Declarations Of Jonathan Blake, BruceEricson
Draft/Edit Replies To Memorandum In Opposition ToPlaintiffs' Motion For Class Certification (Full AndRedacted Versions), Declaration Of Adam Gutride(Full And Redacted Versions), Motion To Seal
Review Order Granting Motion To Seal
Review Request For Briefing.
Date TimekeeperFiled orComp-leted AJG MIRR SAS KER KJS JPM EJM
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05/10/07 21.5
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Draft/Edit Errata Re Reply To Opposition Re Class 05/15/07 .25Certification
Review Notice Of Hearing And Request For 05/16/07 .25Information Re Forrest McKenna.
Review Further Notice Re McKenna. 05/16/07 .25
Prepare For, Attend Motion Hearing Re Motion For 05/17/07 6.5Judgment On The Pleadings
Review Order Granting Defendants' Motion For 05/17/07 .25Judgment On The Pleadings
Review Response In Support Of Request For 05/21/07 .75Information Re Forrest McKenna Filed By FundsDefendants.
Review Response To Request For Briefing Re Ronald 05/21/07 .5Siemers And Loss Causation By Funds Defendants.
Draft/Edit, Confer With Client Re Response In 05/21/07 14.5Support Of Class Certification To Request For FurtherBriefing.
Draft/Edit, Confer With Client Re Response To 05/21/07 10.5Request For Further Briefing Re Forrest McKenna,Declaration Of Adam Gutride
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Pleadings, Hearings Filed orComp-leted AJG MRR SAS KER KJS JPM EJM
Prepare For, Attend Hearing Re Forrest McKenna 05/23/07 4.5 1 5
Review Order Denying Certification Of Forrest 05/23/07 .25 .25 .25McKenna As A Class Representative.
Prepare For, Attend Hearing Re Motion To Certify 05/24/07 14.75 16.5 10Class
Draft/Edit Declaration Of Ronald Siemers Amending 05/25/07 7.5 .5Lead Plaintiffs Certification
Review Request For Information 05/30/07 .25 .25 .25
Review Response To Request For Information Re Fees 05/31/07 .25 .25 .25By Funds Defendants.
Draft/Edit Response To Order Requesting Further 05/31/07 6.5 .5 2.5Information.
Review Transcript Of Proceedings Held On 04/05/07 05/31/07 .25Before Judge William Alsup.
Review Order Granting Class Certification And 06/01/07 .5 .5 .5Confirming Class Representative And Class Counsel
Negotiate, Edit Stipulation And [Proposed] Order 06/04/07 .5 .25Regarding Extension Of Time For Submission OfProposed Form Of Class Notice ^ ^ ^
Date Timekeeper
Pleadings, Hearings Filed orComp-leted AJG MRR SAS KER KJS JPM EJM
Review Order Regarding Extension Of Time For 06/05/07 .25 .25Submission Of Proposed Form Of Class Notice.
Prepare For, Attend Settlement Conference, Draft 06/14/07 24 20 12Settlement Conference Statement and DamagesAnalysis
Negotiate, Edit Stipulation And [Proposed] Order 06/14/07 .5 .25Regarding Extension Of Time For Submission OfProposed Form Of Class Notice
Review Order Denying Stipulated Request For 06/15/07 .25 .25Extension Of Time
Draft, Edit Response To Order Re Form, Method And 06/15/07 1 .5Content Of Class Notice
Review Notice And Order Setting Further Settlement 06/18/07 .25Conference
Review Order Re Proposed Class Notice. 06//07 .25 I .25
Draft, Negotiate, Edit Joint Response To Order Re 06/25/07 1.5 .5Class Notice With Revised Proposed Class Notice)
Draft, Edit Errata Re Corrected Proposed Class Notice 06/26/07 .25 .5
Review Order Re Proposed Notice And Method Of 06/27/07 .25 .25Notice.
Pleadings, Hearings
Prepare For, Attend Settlement Conference
Negotiate, Draft, Edit, Confer With Client Re:Stipulation Of Settlement By Funds Defendants.(Attachments: # 1 Exhibit 1 - [Proposed] PrelimOrder# 2 Exhibit 2 - Not Of Sett (Short)# 3 Exhibit 3 -Not Of Sett (Long)# 4 Exhibit 4 - [Prop] Plan# 5Exhibit A To Exhibit 4# 6 Exhibit 5 - [Prop] FinalOrder# 7 Exhibit 6 - Prospectus Lang# 8 Exhibit 7 -Sai Discl)
Review Notice Of Hearing On Request ForPreliminary Approval
Draft/Edit Response To Order Requesting ExpertReport In Connection With Preliminary Approval OfSettlement
Prepare For, Attend Motion Hearing Re PreliminaryApproval
Draft/Edit Lead Plaintiff s Supplemental SubmissionRe Preliminary Approval Of Settlement (Full AndRedacted Versions), Declaration Of Adam Gutride InSupport (Full And Redacted Versions), Motion ToSeal, Errata Re Same
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DateFiled orComp-leted
Review Order Granting Motion To Seal 07/30/07
Review Letter From Gilbert R. Serota Re United States 07/31/07Court Of Appeals Opinion)
Review Order Re Amended Forms 08/01/07
Draft, Edit, Negotiate Joint Submission Re Class OFNotice In Response To August 1, 2007 Order
Review Order Preliminarily Approving Settlement. OF
Draft, Negotiate Edit Joint Submission Regarding OFProposed Settlement Schedule And Revised DisclosureLanguage In Response To The Court's August 3, 2007Order
Draft, Edit Notice Of Voluntary Dismissal Without OFPrejudice By Plaintiff Forrest McKenna
Review Order Preliminarily Approving Settlement, OFNotice, And Setting Fairness Hearing.
Review Transcript Of Proceedings Held On 05/24/07 OFBefore Judge William Alsup
Review Transcript Of Proceedings Held On 07/11/07 OFBefore Judge William Alsup.
Timekeeper
AJG MIRR SAS KER KJS JPM EJM
1) 5
Date Timekeeper
Pleadings, Hearings Filed orComp-leted AJG MIRR SAS KER KJS JPM EJM
Draft, Edit Motion for Attorneys ' Fees and Expenses 12/21/07 7.5 6.25
Draft, Edit Declaration of Adam Gutride In Support Of 12/21/07 11.5 1.5 1.75 .25 .25 .25 .25Motion for Attorneys' Fees and Expenses
Draft, Edit Declaration of Ronald Siemers In Support 12/21/07 2.5 .5of Motion for Attorneys' Fees and Expenses
TOTAL 491.75 559.25 323.25 1 0.5 12 55.5
EXHIBIT C
Discovery
Draft initial disclosures, confer with client re same,review Defendants' initial disclosures
Draft, review answers to, meet and confer regarding:First set of interrogatories to all Defendants
Draft, review answers to, meet and confer regarding:Second Set of interrogatories to Funds Defendants
Draft, review answers to, meet and confer regarding:Second Set of interrogatories to Wells FargoInvestments
Draft, review answers to, meet and confer regarding:Second Set of interrogatories to Wells Fargo & Co.
Draft, review answers to, meet and confer regarding:Second Set of interrogatories to H.D. Vest Investments
Draft, review answers to, meet and confer regarding:Third set of interrogatories to funds defendants
Review answers to, meet and confer regarding first setof requests for production to Defendants
Draft, review answers to, meet and confer regarding:Second set of requests for production to Defendants
Draft, review answers to, meet and confer regarding:
Timekeeper
AJG MRR SAS KER KJS JPM EJM
.75 7 .25
16.5 1.5 3.5
8.5 4.5 1.5
4.5 2 .75
.75 .25
5.5 1
17.5 1.25 1
12.5 2 1.5
13.5 1.25
1.5 6.5
Discovery
Third set of requests for production to Defendants
Draft, review answers to, meet and confer regarding:subpoenas to third party shelf-space fund issuers;review documents produced
Draft, review answers to, meet and confer regarding:subpoenas to third party broker-dealers for WellsFargo funds; review documents produced
Draft, review answers to, meet and confer regarding:subpoena to Wells Fargo Investments
Review, communicate with clients re, draft answers to, 2meet/confer with defendants re answers to first set ofrequests for admission to Forest McKenna
Review, communicate with clients re, draft answers to,meet/confer with defendants re answers to first set ofrequests for admission to Ronald Siemers
Review, communicate with clients re, draft answers to, 2meet/confer with defendants re answers to first set ofrequests for production to Forest McKenna; reviewand produce documents
Review, communicate with clients re, draft answers to,meet/confer with defendants re answers to first set ofinterrogatories to Forest McKenna
Timekeeper
AJG MRR SAS KER KJS JPM EJM
Discovery
Review, communicate with clients re, draft answers to,meet/confer with defendants re answers to first set ofinterrogatories to Ronald Siemers
Review, communicate with clients re, draft answers to,meet/confer with defendants re answers to second setof interrogatories to Ronald Siemers
Review and produce additional documents on behalf ofRonald Siemers
Review documents: Guinn Eiland (HD Vest)
Review documents: Joyce Kulasxa (HD Vest)
Review documents: Alan Robbins (HD Vest)
Review documents produced by Wells FargoInvestments ( 183,000 pages)
Review documents produced by HD Vest Investments(6100 pages)
Review documents produced by Wells Fargo FundsManagement (30,000 hard copy pages, 36,000electronic pages, plus databases/spreadsheets)
AJG MRR
3.5
2.5
1
3.5
1.5
1.25
3.5 18
1. 25
25 .25
Review documents produced by Wells Capital .2Management (30 pages)
L
1
1
1
50 84.5 2 82.25 153
Timekeeper
SAS KER KJS JPM EJM
25
Discovery
Review documents produced by Stephens, Inc. (1500pages)
Timekeeper
AJG MRR SAS KER KJS JPM EJM
2.5
Review documents produced by Wells Fargo Funds 5.Trust (23,000 pages)
Prepare for, attend deposition of Ronald Siemers(includes travel time)
Prepare for, attend deposition of Forrest McKenna 1 i(includes travel time)
Prepare for, attend deposition of Courtney Unser(includes travel time)
Prepare for, attend deposition of Karla Rabush WFFM 1(30(b)(6) deposition (includes Y2 of travel time fromNYC to SF for MRR, as MRR scheduled deposition atsame time as hearing on another matter in SF)
Prepare for, attend deposition of Sean Faeth WFI 30b6 7deposition (includes travel time for MRR)
Prepare for, attend deposition of Sean Havlin 1 C(deposition scheduled the same week as lead plaintiffSiemers to reduce travel costs to class)
Prepare for, attend deposition of Richard Blank 7.Stephens 30b6 deposition
TimekeeperDiscovery
AJG MRR SAS KER KJS JPM EJM
Prepare for, attend deposition of Lincoln Yersin WFI 12.5 730b6 deposition
Prepare for, attend deposition of Cara Peck (includes 38.5travel time)
Prepare for, attend deposition of Mike Hogan 11.5
Negotiate re, review declaration of Bruce Hyatt in lieu 3.5of deposition
Draft, edit subjects for expert discovery 2.5 .25 1
Review Defendants' subjects for expert discovery .25 .25
Draft deposition notices (including 30b6 topics); 2.5 3.25 3correspondence re deposition scheduling
TOTAL 214.25 286.5 161 84.5 15.25 101.75 153
EXHIBIT D
TimekeeperSettlement, Other
AJG MIRK SAS
Select claims administrator 2.5 1.5
Implement, monitor, follow up re settlement notice; 3.5 3.25meet confer re same
Specifications for claim form, settlement website and 18.5automated phone system, review and test same
Answer class member & media inquiries re settlement 2.5 1
Supervise, answer questions from, claim administrator; 12.5review weekly reports
Press release re first motion to dismiss 2.5 .5 .5
Press release, advertisements re motion to dismiss HD 2 .5 .5Vest
Press release re second motion to dismiss 3.5 .5 .5
Press release re tentative ruling on leave to amend 2.5 .5 .5
Engagement letters, termination letters 3.75 1.25
Research experts, meetings w/ potential experts 2.5 4.5
TOTAL 56.25 6.5 9
EXHIBIT E
Expenses AmountPrinting, Copying and Reproduction $6,530.09De osition/Transcri ts/Notice $19,600.98Fax/Phone $182.16Filing/Witness Fees $933.50Parking $379.00Postage/Delivery $681.90Process Serving $2,342.26Research $175.84Supplies $135.41Travel/Meals/Transportation $20,585.26Contract Paralegals/3IParty Legal $2,532.50
Total $54,078.90