Contract analysis

1. Case Reactivation & Lift Stay | Prepare motion/stipulation to lift stay and set case management schedule | 2 | $1,790 | 1 | $850 | 5 | $3,125 | 3 | $1,575 | 11 | $7,340 | $0 | Coordinate with Pratchett, Huang & Solano LLP on scheduling

1. Case Reactivation & Lift Stay | Case management conference preparation and attendance | 3 | $2,685 | 0 | $0 | 3 | $1,875 | 2 | $1,050 | 8 | $5,610 | $0 | Appear before Hon. Patricia R. Wainwright, Dept. 302

1. Case Reactivation & Lift Stay | Client meeting with Priya Chattopadhyay and Margot Ellison-Yee re: litigation strategy | 3 | $2,685 | 2 | $1,700 | 2 | $1,250 | 0 | $0 | 7 | $5,635 | $0 PHASE 1 SUBTOTAL | 8 | $7,160 | 3 | $2,550 | 10 | $6,250 | 5 | $2,625 | 26 | $18,585 | $0

2. Limited discovery — Written | Draft and serve interrogatories (set of 15) | 1 | $895 | 0 | $0 | 4 | $2,500 | 8 | $4,200 | 13 | $7,595 | $150 | Focused on WGFT's interpretation of Gift Instrument § 7.2 and § 3.1

2. Limited discovery — Written | Draft and serve requests for production (set of 20) | 1 | $895 | 0 | $0 | 4 | $2,500 | 10 | $5,250 | 15 | $8,645 | $150 | Trust records, communications re: BATRI, grant administration files

2. Limited discovery — Written | Review and respond to WGFT written discovery | 2 | $1,790 | 0 | $0 | 8 | $5,000 | 12 | $6,300 | 22 | $13,090 | $0 | Anticipate 2 sets from opposing counsel

2. Limited discovery — Written | Meet and confer on discovery disputes (if any) | 2 | $1,790 | 0 | $0 | 3 | $1,875 | 2 | $1,050 | 7 | $4,715 | $0 PHASE 2 SUBTOTAL | 6 | $5,370 | 0 | $0 | 19 | $11,875 | 32 | $16,800 | 57 | $34,045 | $300

3. Depositions | Prepare for and take deposition of Roland Whitfield-Garner (Trustee) — 1 day | 4 | $3,580 | 0 | $0 | 10 | $6,250 | 8 | $4,200 | 22 | $14,030 | $3,500 | Court reporter, videographer, and transcript costs

3. Depositions | Prepare for and take deposition of Adrienne Garner-Bosch (Co-Trustee) — 1 day | 4 | $3,580 | 0 | $0 | 10 | $6,250 | 8 | $4,200 | 22 | $14,030 | $3,500 | Court reporter, videographer, and transcript costs

3. Depositions | Defend deposition of Margot Ellison-Yee (EF Executive Director) — 1 day | 6 | $5,370 | 0 | $0 | 6 | $3,750 | 4 | $2,100 | 16 | $11,220 | $500 | Preparation and attendance

3. Depositions | Defend deposition of Priya Chattopadhyay (EF General Counsel) — 1 day (if noticed) | 4 | $3,580 | 0 | $0 | 6 | $3,750 | 4 | $2,100 | 14 | $9,430 | $500 | Contingent — may not be noticed PHASE 3 SUBTOTAL | 18 | $16,110 | 0 | $0 | 32 | $20,000 | 24 | $12,600 | 74 | $48,710 | $8,000

4. Expert Witness (Contingent) | Retain and consult with expert on charitable purpose analysis / cy pres standards | 2 | $1,790 | 1 | $850 | 6 | $3,750 | 4 | $2,100 | 13 | $8,490 | $25,000 | Expert retainer and report preparation; may not be needed if court treats as pure legal question

4. Expert Witness (Contingent) | Expert deposition preparation and defense (if opposing expert retained) | 3 | $2,685 | 0 | $0 | 5 | $3,125 | 3 | $1,575 | 11 | $7,385 | $5,000 | Contingent on whether WGFT retains expert PHASE 4 SUBTOTAL | 5 | $4,475 | 1 | $850 | 11 | $6,875 | 7 | $3,675 | 24 | $15,875 | $30,000 | Entire phase contingent; may be $0 if not required

5. Motion for Summary Judgment — EF's Motion | Research and draft memorandum of points and authorities | 8 | $7,160 | 0 | $0 | 30 | $18,750 | 20 | $10,500 | 58 | $36,410 | $0 | Primary arguments: cy pres (Cal. Prob. Code § 15409), equitable deviation (Cal. Prob. Code § 15403), impracticability of BATRI

5. Motion for Summary Judgment — EF's Motion | Prepare separate statement of undisputed material facts | 2 | $1,790 | 0 | $0 | 8 | $5,000 | 10 | $5,250 | 20 | $12,040 | $0 | Key facts: Gift Instrument §§ 3.1 and 7.2; OUSD/SFUSD withdrawal; EF Board wind-down resolution of 12/31/2021

5. Motion for Summary Judgment — EF's Motion | Compile and authenticate evidentiary support (declarations, exhibits) | 1 | $895 | 0 | $0 | 5 | $3,125 | 12 | $6,300 | 18 | $10,320 | $500 | Gift Instrument, BATRI records, school district correspondence, board minutes

5. Motion for Summary Judgment — EF's Motion | Partner review and revision cycles | 8 | $7,160 | 3 | $2,550 | 4 | $2,500 | 0 | $0 | 15 | $12,210 | $0 PHASE 5 SUBTOTAL | 19 | $17,005 | 3 | $2,550 | 47 | $29,375 | 42 | $22,050 | 111 | $70,980 | $500

6. Oppose WGFT Cross-Motion (Contingent) | Draft opposition to WGFT cross-motion for summary judgment (reversion under § 7.2) | 5 | $4,475 | 0 | $0 | 18 | $11,250 | 12 | $6,300 | 35 | $22,025 | $0 | Anticipate WGFT argues § 7.2 reversion clause is self-executing

6. Oppose WGFT Cross-Motion (Contingent) | Prepare responsive separate statement | 1 | $895 | 0 | $0 | 5 | $3,125 | 8 | $4,200 | 14 | $8,220 | $0

6. Oppose WGFT Cross-Motion (Contingent) | Partner review | 5 | $4,475 | 2 | $1,700 | 2 | $1,250 | 0 | $0 | 9 | $7,425 | $0 PHASE 6 SUBTOTAL | 11 | $9,845 | 2 | $1,700 | 25 | $15,625 | 20 | $10,500 | 58 | $37,670 | $0 | Contingent on WGFT filing cross-motion

7. Reply Brief and Hearing Preparation | Draft reply in support of EF's MSJ | 4 | $3,580 | 0 | $0 | 12 | $7,500 | 8 | $4,200 | 24 | $15,280 | $0

7. Reply Brief and Hearing Preparation | Prepare for and attend MSJ hearing before Hon. Wainwright | 6 | $5,370 | 0 | $0 | 6 | $3,750 | 2 | $1,050 | 14 | $10,170 | $0

7. Reply Brief and Hearing Preparation | Post-hearing supplemental briefing (if ordered) | 3 | $2,685 | 0 | $0 | 6 | $3,750 | 4 | $2,100 | 13 | $8,535 | $0 | Contingent PHASE 7 SUBTOTAL | 13 | $11,635 | 0 | $0 | 24 | $15,000 | 14 | $7,350 | 51 | $33,985 | $0

8. Case Management & Administration | Ongoing client communications and strategy calls | 4 | $3,580 | 2 | $1,700 | 6 | $3,750 | 2 | $1,050 | 14 | $10,080 | $0 | Throughout reactivation period

8. Case Management & Administration | Internal team meetings and matter management | 2 | $1,790 | 1 | $850 | 4 | $2,500 | 3 | $1,575 | 10 | $6,715 | $0

8. Case Management & Administration | Billing, budgeting, and client reporting | 0 | $0 | 4 | $3,400 | 2 | $1,250 | 0 | $0 | 6 | $4,650 | $0 PHASE 8 SUBTOTAL | 6 | $5,370 | 7 | $5,950 | 12 | $7,500 | 5 | $2,625 | 30 | $21,445 | $0 GRAND TOTAL — ALL PHASES | 86 | $76,970 | 16 | $13,600 | 180 | $112,500 | 149 | $78,225 | 431 | $281,295 | $38,800 [sheet: Budget Summary] Phase | Estimated Hours | Estimated Attorney Fees

1. Case Reactivation & Lift Stay | 26 | $18,585 | $0 | $15,000 | $22,000 | No

2. Limited discovery — Written | 57 | $34,045 | $300 | $28,000 | $40,000 | No

3. Depositions | 74 | $48,710 | $8,000 | $40,000 | $60,000 | Partially — 4th deposition contingent

4. Expert Witness (Contingent) | 24 | $15,875 | $30,000 | $0 | $45,000 | Yes — entire phase contingent

5. Motion for Summary Judgment — EF's Motion | 111 | $70,980 | $500 | $60,000 | $75,000 | No

6. Oppose WGFT Cross-Motion (Contingent) | 58 | $37,670 | $0 | $0 | $40,000 | Yes — contingent on WGFT cross-motion

7. Reply Brief and Hearing Preparation | 51 | $33,985 | $0 | $28,000 | $38,000 | Partially — supplemental briefing contingent

8. Case Management & Administration | 30 | $21,445 | $0 | $18,000 | $25,000 | No SUBTOTAL — Reactivation Through MSJ | 431 | $281,295 | $38,800 | $175,000 | $250,000 Fees Billed to Date (Through 12/31/2024) | $287,450 | $287,450 | $287,450 Outstanding A/R Against Billed Fees | $13,350 | To be collected GRAND TOTAL — MATTER INCEPTION THROUGH MSJ | $462,450 | $537,450