[sheet: Cover & Summary]

Field	Value
Document Title	Litigation Budget Memorandum — Projected Costs to Reactivate Through Dispositive Motion
Matter Name	Estuary Foundation v. The Whitfield-Garner Family Trust
Case Number	CGC-22-599481
Court / Department	Superior Court of California, County of San Francisco, Dept. 302
Assigned Judge	Hon. Patricia R. Wainwright
C&H Matter Number	1028-00001
Client	Estuary Foundation
Client Contact	Priya Chattopadhyay, General Counsel
Client Address	1440 Embarcadero Way, Suite 300, San Francisco, CA 94107
Opposing Party	The Whitfield-Garner Family Trust
Opposing Counsel	Pratchett, Huang & Solano LLP (Victoria Huang, Lead Partner; Derek Solano Jr., Senior Associate)
Opposing Counsel Address	555 California Street, 28th Floor, San Francisco, CA 94104
Prepared By	Francesca Morano (Billing Partner) and Simone Laroche (Lead Associate)
Reviewed By	Douglas Carmichael (Responsible Partner)
Date Prepared	December 2024
Matter Status	Dormant — stayed by Stipulation and Order entered September 16, 2022; tenth joint status report filed March 14, 2025; next status report due June 13, 2025
Total Restricted Funds in Dispute (All Donors)	$4,700,000
WGFT Funds in Dispute	$1,700,000 ($700,000 unexpended disbursed + $1,000,000 undisbursed Tranche 4)
WGFT Claimed Interest	7% per annum on $1,700,000 from April 28, 2022 (~$119,000/year)
Total C&H Fees Billed Through 12/31/2024	$287,450
Total C&H Fees Collected Through 12/31/2024	$274,100
Outstanding Accounts Receivable	$13,350
Estimated Additional Fees to Reactivate Through MSJ	$175,000 – $250,000
Estimated Total Fees (Cumulative)	$462,450 – $537,450

[sheet: Billing Rates]

Timekeeper	Role	Title	Hourly Rate
Douglas Carmichael	Responsible Partner	Partner, Litigation (General)	$895
Francesca Morano	Billing Partner	Partner, Litigation (General)	$850
Simone Laroche	Lead Associate	Senior Associate, Litigation (General)	$625
Jeffrey Park	Working Associate	Associate, Litigation (General)	$525

[sheet: Funds Analysis]

Donor / Source	Original Restricted Amount	Amount Expended on BATRI	Unexpended / In Dispute	Consent to Reallocation	Notes
Whitfield-Garner Family Trust — Tranche 1 (June 2018)	$1,500,000	$1,500,000	$0	No — sole objecting party	Disbursed; fully expended on BATRI
Whitfield-Garner Family Trust — Tranche 2 (July 2019)	$1,250,000	$1,050,000	$200,000	No	Disbursed; partially expended
Whitfield-Garner Family Trust — Tranche 3 (July 2020)	$1,250,000	$750,000	$500,000	No	Disbursed; partially expended
Whitfield-Garner Family Trust — Tranche 4 (July 2021)	$1,000,000	$0	$1,000,000	No	Never disbursed; held by WGFT
WGFT Total Disbursed	$4,000,000	$3,300,000	$700,000	No	Unexpended balance of disbursed funds
WGFT Total in Dispute (Unexpended + Undisbursed)	$1,700,000	No	$700K unexpended + $1.0M undisbursed Tranche 4
Cascabel Education Fund (2019)	$2,000,000	$0	$2,000,000	Yes — consented	Restricted to BATRI; donor has consented to reallocation
Newhall-Sievert Foundation (2020)	$1,000,000	$0	$1,000,000	Yes — consented	Restricted to BATRI; donor has consented to reallocation
TOTAL ALL DONORS	$8,000,000	$3,300,000	$4,700,000	Total restricted funds subject to declaratory judgment action

[sheet: Interest Accrual]

Period End Date	Days from April 28 2022	Principal	Annual Rate	Cumulative Interest Accrued	Total Claimed Amount
April 28, 2022	0	$1,700,000	7.00%	$0	$1,700,000
December 31, 2022	247	$1,700,000	7.00%	$80,493	$1,780,493
December 31, 2023	612	$1,700,000	7.00%	$199,493	$1,899,493
December 31, 2024	977	$1,700,000	7.00%	$318,493	$2,018,493
June 13, 2025 (Next Status Report)	1,142	$1,700,000	7.00%	$372,164	$2,072,164
December 31, 2025 (Projected MSJ Hearing)	1,343	$1,700,000	7.00%	$437,493	$2,137,493

[sheet: Budget Detail]

Phase / Task	Subtask	Carmichael Hours	Carmichael Fees @ $895	Morano Hours	Morano Fees @ $850	Laroche Hours	Laroche Fees @ $625	Park Hours	Park Fees @ $525	Total Hours	Total Fees	Hard Costs / Disbursements	Notes
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	Estimated Hard Costs / Disbursements	Low Estimate	High Estimate	Contingent?
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

[sheet: Cover & Summary]
Field | Value
Document Title | Litigation Budget Memorandum — Projected Costs to Reactivate Through Dispositive Motion
Matter Name | Estuary Foundation v. The Whitfield-Garner Family Trust
Case Number | CGC-22-599481
Court / Department | Superior Court of California, County of San Francisco, Dept. 302
Assigned Judge | Hon. Patricia R. Wainwright
C&H Matter Number | 1028-00001
Client | Estuary Foundation
Client Contact | Priya Chattopadhyay, General Counsel
Client Address | 1440 Embarcadero Way, Suite 300, San Francisco, CA 94107
Opposing Party | The Whitfield-Garner Family Trust
Opposing Counsel | Pratchett, Huang & Solano LLP (Victoria Huang, Lead Partner; Derek Solano Jr., Senior Associate)
Opposing Counsel Address | 555 California Street, 28th Floor, San Francisco, CA 94104
Prepared By | Francesca Morano (Billing Partner) and Simone Laroche (Lead Associate)
Reviewed By | Douglas Carmichael (Responsible Partner)
Date Prepared | December 2024
Matter Status | Dormant — stayed by Stipulation and Order entered September 16, 2022; tenth joint status report filed March 14, 2025; next status report due June 13, 2025
Total Restricted Funds in Dispute (All Donors) | $4,700,000
WGFT Funds in Dispute | $1,700,000 ($700,000 unexpended disbursed + $1,000,000 undisbursed Tranche 4)
WGFT Claimed Interest | 7% per annum on $1,700,000 from April 28, 2022 (~$119,000/year)
Total C&H Fees Billed Through 12/31/2024 | $287,450
Total C&H Fees Collected Through 12/31/2024 | $274,100
Outstanding Accounts Receivable | $13,350
Estimated Additional Fees to Reactivate Through MSJ | $175,000 – $250,000
Estimated Total Fees (Cumulative) | $462,450 – $537,450
[sheet: Billing Rates]
Timekeeper | Role | Title | Hourly Rate
Douglas Carmichael | Responsible Partner | Partner, Litigation (General) | $895
Francesca Morano | Billing Partner | Partner, Litigation (General) | $850
Simone Laroche | Lead Associate | Senior Associate, Litigation (General) | $625
Jeffrey Park | Working Associate | Associate, Litigation (General) | $525
[sheet: Funds Analysis]
Donor / Source | Original Restricted Amount | Amount Expended on BATRI | Unexpended / In Dispute | Consent to Reallocation | Notes
Whitfield-Garner Family Trust — Tranche 1 (June 2018) | $1,500,000 | $1,500,000 | $0 | No — sole objecting party | Disbursed; fully expended on BATRI
Whitfield-Garner Family Trust — Tranche 2 (July 2019) | $1,250,000 | $1,050,000 | $200,000 | No | Disbursed; partially expended
Whitfield-Garner Family Trust — Tranche 3 (July 2020) | $1,250,000 | $750,000 | $500,000 | No | Disbursed; partially expended
Whitfield-Garner Family Trust — Tranche 4 (July 2021) | $1,000,000 | $0 | $1,000,000 | No | Never disbursed; held by WGFT
WGFT Total Disbursed | $4,000,000 | $3,300,000 | $700,000 | No | Unexpended balance of disbursed funds
WGFT Total in Dispute (Unexpended + Undisbursed) | $1,700,000 | No | $700K unexpended + $1.0M undisbursed Tranche 4
Cascabel Education Fund (2019) | $2,000,000 | $0 | $2,000,000 | Yes — consented | Restricted to BATRI; donor has consented to reallocation
Newhall-Sievert Foundation (2020) | $1,000,000 | $0 | $1,000,000 | Yes — consented | Restricted to BATRI; donor has consented to reallocation
TOTAL ALL DONORS | $8,000,000 | $3,300,000 | $4,700,000 | Total restricted funds subject to declaratory judgment action
[sheet: Interest Accrual]
Period End Date | Days from April 28 2022 | Principal | Annual Rate | Cumulative Interest Accrued | Total Claimed Amount
April 28, 2022 | 0 | $1,700,000 | 7.00% | $0 | $1,700,000
December 31, 2022 | 247 | $1,700,000 | 7.00% | $80,493 | $1,780,493
December 31, 2023 | 612 | $1,700,000 | 7.00% | $199,493 | $1,899,493
December 31, 2024 | 977 | $1,700,000 | 7.00% | $318,493 | $2,018,493
June 13, 2025 (Next Status Report) | 1,142 | $1,700,000 | 7.00% | $372,164 | $2,072,164
December 31, 2025 (Projected MSJ Hearing) | 1,343 | $1,700,000 | 7.00% | $437,493 | $2,137,493
[sheet: Budget Detail]
Phase / Task | Subtask | Carmichael Hours | Carmichael Fees @ $895 | Morano Hours | Morano Fees @ $850 | Laroche Hours | Laroche Fees @ $625 | Park Hours | Park Fees @ $525 | Total Hours | Total Fees | Hard Costs / Disbursements | Notes
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 | Estimated Hard Costs / Disbursements | Low Estimate | High Estimate | Contingent?
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

[sheet: Cover & Summary]

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