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1 FILED: NEW YORK COUNTY CLERK 06/21/ :54 PM INDEX NO /2016 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 06/21/2016 Exhibit E
2 KLEINBERG, KAPLAN, WOLFF & COHEN, P.C. 551 Fifth Avenue 18th Floor New York, NewYork Prospector Capital Partners, Inc. (f/kla Trump Your Competition, Inc.) 297 mkingsbury Grade Road, Suite 1136 MB4470 Lake Tahoe, NV January 15, 2016 Bill Number File Number FOR PROFESSIONAL SERVICES Thru December 31, 2015 Re: D.J. Trump v. Trump Your Competition LEGAL SERVICES 11/02/15 SRP Discussing background and issues, including procedures and service 11/04/15 NDW Prospector Capital Partners -- Reviewing Trademark Trial and Appeal Board proceedings and materials regarding D. Trump's opposition and Southern District's rules regarding subpoenas in aid of Trademark Trial and Appeal Board proceedings 11/05/15 NDW Conferring with D. Schechter regarding proposed form of subpoena and related notices for Trump's deposition 11/05/15 DMS Reading and reviewing communications with R. Underhill; conferring regarding same; reviewing draft notice of deposition; conferring regarding means of service of process; conducting research in connection with same; preparing for same 11/05/15 SRP Discussing service issue and reviewing federal treatise 11/06/15 NDW Reviewing and revising proposed cover letter and related notices and subpoena; conferring with D. Schechter and Rod Underhill regarding same 11/06/15 DMS Conferring regarding H. Underhill, service of process, and other issues; drafting necessary paperwork for SONY; conferring regarding same; instructing paralegal with respect to same Page 1
3 Re: D.J. Trump v. Trump Your Competition 11/09/15 NOW 11/09/15 OMS 11/10/15 NOW 11/25/15 NOW 11/30/15 NS 12/02/15 NOW 12/02/15 NS 12/04/15 NOW 12/04/15 NS 12/07/15 NOW 12/07/15 NS 12/08/15 NOW 12/08115 NS 12/09/15 NOW 12/09/15 NS 12/09/15 HG Follow~up regarding issuance of Subpoena Supervising and finalizing SONY subpoena; conferring regarding same; Conferring by phone with process servers, paralegals and clerk's office; follow~ups regarding issuance and service of the subpoena on D. Trump Reviewing Hughes Hubbard's objections to the Trump subpoena Researching and conferring and corresponding, including with co-counsel, with respect to response to D. Trump's counsel's refusal to produce him for deposition Reviewing proposed response to Hughes Hubbard Corresponding and conferring with respect to response to Trump's counsel's letter concerning trial testimony and merits of Trump's opposition Follow-ups regarding proposed motion to compel Conferring and corresponding with respect to efforts to amicably resolve dispute over subpoena and background information concerning registration in anticipation of drafting motion to compel Organizing exhibits, outlining motion to compel; conferring with N. Sreeprakash regarding same Conferring with respect to background information and motion to compel Organizing proposed exhibits and materials for the Trump motion to compel; conferring with N. Sreeprakash regarding same Researching and drafting motion to compel compliance with subpoena and conferring with respect to the same Reviewing and revising Declaration and brief on Motion to Compel; Researching and drafting motion to compel compliance with subpoena and conferring with respect to the same;, conferring and corresponding with respect to commencement of miscellaneous proceeding and completing requisite forms Reviewing and editing draft memorandum of law, declaration of N. Sreeprakash and exhibits, rule 7.1 statement, notice of motion to compel and miscellaneous cover sheet; researching ECF rules for filing miscellaneous actions Page 2
4 12/1 0/15 NOW 12/10/15 NS 12/10/15 HG 12/11/15 NOW 12111/15 NS 12/11/15 HG 12/14115 NOW 12/14/15 NS 12/14/15 HG 12/15/15 NOW 12/15/15 NS 12/16/15 NOW Reviewing and revising motion papers and conferring with N. Sreepakash and H. Goldsmith regarding same Conferring with respect to, drafting certificate of service in connection with, overseeing service, and overseeing initiation of miscellaneous proceeding and filing of motion to compel papers Traveling to and from Court to file and re-file motion to compel and commencement of miscellaneous case and supporting documents; conferring with miscellaneous clerk and N. Sreeprakash regarding filing procedures; reviewing certificate of service; editing commencement documents; obtaining miscellaneous case docket number; retrieving new case docket from Pacer Follow-ups regarding pending motion; conferring with N. Sreeprakash regarding same Conferring and corresponding, including with clerk of court, with respect to preparation and filing of electronic copies of initiating papers Retrieving docket from Pacer to locate file stamped motion papers; telephoning SONY ECF clerk regarding status of uploading motion papers to Pacer; conferring with N. Sreeprakash regarding copies of motion papers Reviewing correspondence regarding scheduling Conferring with respect to requisite court filings and strategy for motion to compel Retrieving file stamped copies of motion to compel from Pacer; circulating same; reviewing draft notices of appearance for N. Sreeprakash and N. Wolff; e-filing same; telephoning SONY part clerk regarding filing of Rule 7.1 Disclosure Statement; e-filing Rule 7.1 Disclosure Statement; downloading and circulating file stamped copies Reviewing correspondence regarding scheduling and issues respecting adjournment of trial dates Conferring with co-counsel with respect to strategy in TTAB proceeding; corresponding with counsel for Trump with respect to pending motion to compel Conferring with N. Sreeprakash regarding next steps and tactics on motion to compel Page 3
5 Re: D.J. Trump v. Trump Your Competition 12/16/15 NS Conferring and corresponding, including with counsel for Trump and co-counsel, with respect to motion to compel and potential adjournment as well as procedural history relevant to motion to compel and scheduling issues 12117/15 NOW Reviewing Trademark Trial and Appeal Board's filings and Trump's request for adjournment; conferring with N. Sreeprakash regarding same 12/17/15 NS Reviewing letter motion by Trump to adjourn oral argument and enlarge time to oppose motion to compel; draft letter opposing Trump motion for additional time and corresponding with respect to the same 12/18/15 NOW Reviewing and revising correspondence; conferring with N. Sreeprakash regarding next steps and tactics on motion to compel 12/18/15 NS Reviewing, revising, and conferring and corresponding with respect to correspondence with Judge Woods in response to Trump's counsel's request for additional time; conferring with co-counsel with respect to strategy for motion to compel and in TTAB 12/18/15 HG Retrieving from Pacer a notice of appearance by D. Weiner, Trump's motion to extend time to respond, Trump Your Competition's letter to J. Woods in opposition to Trump's motion for extension of time and judge's order granting adjournment; circulating and reviewing same 12/21/15 NOW Reviewing correspondence regarding possible settlement; conferring with N. Sreeprakash regarding same 12/22/15 NS Conferring with co-counsel with respect to settlement discussions and TTAB's suspension of schedule and implications for pending motion to compel and TTAB proceeding generally 12/23/15 NS Corresponding with co-counsel with respect to TTAB schedule 12/29/15 NS Reviewing correspondence concerning TTAB proceedings and pending motion to compel Page 4
6 TOTAL LEGAL SERVICES $24, LEGAL SERVICES SUMMARY Norris D. Wolff Netra Sreeprakash David M. Schechter Hannah Goldsmith Steven R. Popofsky DISBURSEMENTS Hrs 785/hr Hrs 540/hr 2.60 Hrs 445/hr 7.20 Hrs 220/hr 0.50 Hrs 625/hr Hrs $8, $13, $1, $1, $ $24, TOTAL DISBURSEMENTS LESS PRIOR PAYMENTS $68.98 $13, TOTAL THIS BILL $11, PageS
X Index No. Date Purchased: Plaintiff, Defendants.
FILED: NEW YORK COUNTY CLERK 06/21/2016 01:54 PM INDEX NO. 653281/2016 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/21/2016 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK -------------------------------X
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