[sheet: Cover]
Field | Value
Prepared By | Samuel Eklund, Billing Partner — Calderwood & Harkness LLP
Prepared For | Derek Olafson, General Counsel — Redstone Gaming Corp.
Date | January 2025
Matter | Redstone Gaming Corp. v. Grizzly Peak Research LLC et al.
Case No. | 24STCV-01892
Court | Superior Court of California, County of Los Angeles
Presiding Judge | Hon. Karen Yamamoto
Matter Open Date | February 5, 2024
Matter Status | Settlement Executed — Case Closing
Settlement Amount Recovered | $14,750,000.00
Firm | Calderwood & Harkness LLP
Firm Address | 333 South Grand Avenue, Suite 4800, Los Angeles, CA 90071
Client | Redstone Gaming Corp.
Client Address | 8800 Crimson Ridge Parkway, Suite 1200, Las Vegas, NV 89113
Client Contact | Derek Olafson, General Counsel
Fee Arrangement | Modified Hourly — 85% of standard rates; 15% success premium on aggregate fees upon successful settlement or judgment
Billing Period Covered | February 2024 – January 2025
Total discounted Fees | $2,800,623
Success Premium (15%) | $420,093
Total Engagement Fees | $3,220,716
Costs Advanced | $187,450
Grand Total Due | $3,408,166
[sheet: Timekeeper Summary]
Timekeeper | Role | Standard Rate ($/hr) | Discount (%) | Discounted Rate ($/hr) | Hours Billed | Total discounted Fees ($)
Francesca Morano | Responsible Partner | $1,475.00 | 85% | $1,253.75 | 485 | $608,068.75
Samuel Eklund | Billing Partner | $1,425.00 | 85% | $1,211.25 | 310 | $375,487.50
Carlos Espinoza | Lead Associate | $895.00 | 85% | $760.75 | 1,380 | $1,049,835.00
Hannah Brinkley | Working Associate | $725.00 | 85% | $616.25 | 1,245 | $767,231.25
TOTAL | 3,420 | $2,800,622.50
[sheet: Fee Calculation]
Line Item | Amount ($) | Notes
Total discounted Fees (85% of Standard) | $2,800,623 | Sum of all timekeeper fees at discounted rates; see Timekeeper Summary sheet
Success Premium Rate | 15% | Per Engagement Letter dated Feb 5, 2024; triggered upon successful settlement or judgment
Qualifying Event | $14,750,000 Settlement | Settlement Agreement executed Jan 6, 2025; constitutes 'successful settlement' under engagement terms
Success Premium Calculation | $420,093 | $2,800,623 × 15% = $420,093 (rounded)
Total Engagement Fees | $3,220,716 | $2,800,623 + $420,093
Costs Advanced by Firm | $187,450 | Expert fees, deposition transcripts, e-discovery vendor costs; see Costs Detail sheet
Grand Total Due | $3,408,166 | Total Engagement Fees + Costs Advanced ($3,220,716 + $187,450)
[sheet: Costs Detail]
Category | Description | Vendor / Payee | Amount ($)
Expert Fees | Damages expert — event-study analysis, report preparation, deposition prep | Meridian Forensic Economics LLC (Dr. Elena Vostrikova) | $89,500
Deposition Transcripts | Transcription and videography for 14 depositions (Fenchurch, Lin, and others) | Westwood Court Reporting Services Inc. | $42,750
E-discovery Vendor | Document hosting, processing, and review platform for ~87,000 documents produced | Lighthouse Document Technologies LLC | $38,200
Filing Fees & Service of Process | Court filing fees (complaint, FAC, motions), service of process on defendants | Various | $7,800
Travel & Related | Travel expenses for depositions and mediation (Dec 3–4, 2024, Westside Mediation Center) | Various | $5,200
Miscellaneous | Research databases, photocopying, courier services | Various | $4,000
TOTAL COSTS ADVANCED | $187,450
[sheet: Monthly Hours Summary]
Month | Morano Hours | Eklund Hours | Espinoza Hours | Brinkley Hours | Monthly Total Hours | Monthly Total Fees ($)
Feb 2024 | 55 | 25 | 120 | 95 | 295 | $249,843.75
Mar 2024 | 50 | 30 | 145 | 110 | 335 | $281,018.75
Apr 2024 | 45 | 25 | 130 | 100 | 300 | $247,768.75
May 2024 | 50 | 20 | 140 | 105 | 315 | $259,212.50
Jun 2024 | 40 | 25 | 125 | 115 | 305 | $246,306.25
Jul 2024 | 35 | 20 | 100 | 95 | 250 | $202,768.75
Aug 2024 | 40 | 25 | 110 | 120 | 295 | $238,306.25
Sep 2024 | 40 | 30 | 115 | 110 | 295 | $241,600.00
Oct 2024 | 35 | 30 | 120 | 105 | 290 | $236,712.50
Nov 2024 | 40 | 30 | 120 | 100 | 290 | $237,912.50
Dec 2024 | 35 | 30 | 90 | 100 | 255 | $206,500.00
Jan 2025 | 20 | 20 | 65 | 90 | 195 | $152,672.50
TOTAL | 485 | 310 | 1,380 | 1,245 | 3,420 | $2,800,622.50
[sheet: Phase Summary]
Phase | Date Range | Key Milestones | Total Hours | Total Fees ($) | % of Total Fees
Pre-Litigation & Case Opening | Feb 5 – Feb 12, 2024 | Engagement opened; complaint filed Feb 5; litigation hold issued; preliminary case assessment; legal analysis memo | 185 | $149,466.25 | 5.3%
Pleadings (Original & Amended) | Feb 5 – Mar 18, 2024 | Original complaint (Feb 5); First Amended Complaint adding GPCP and Fenchurch (Mar 18) | 280 | $225,785.00 | 8.1%
Anti-SLAPP Motion Practice | Apr 12 – Jun 7, 2024 | Defendants' anti-SLAPP motion filed Apr 12; opposition filed May 10; denied by Judge Yamamoto Jun 7 | 420 | $338,677.50 | 12.1%
Discovery | Jun – Nov 2024 | 14 depositions; ~87,000 documents produced; 3 discovery motions; expert retention (Vostrikova, Jul 1); expert reports exchanged Sep 9 | 1,450 | $1,178,383.75 | 42.1%
Motion for Summary Judgment | Oct 22 – Nov 15, 2024 | Defendants' MSJ filed Oct 22; opposition filed Nov 5; denied Nov 15 | 380 | $306,678.75 | 11.0%
Mediation & Settlement Negotiation | Nov 20 – Dec 9, 2024 | Pre-mediation strategy; mediation brief; mediation Dec 3–4 before Hon. Matsuda (Ret.); term sheet signed Dec 4; papering timeline letter Dec 9 | 350 | $283,548.75 | 10.1%
Settlement Papering & Case Closing | Dec 9, 2024 – Jan 2025 | Settlement Agreement executed Jan 6, 2025; escrow agreement; corrective statements; stipulated dismissal & injunction; billing and closing memos | 355 | $318,082.50 | 11.3%
TOTAL | Feb 2024 – Jan 2025 | 3,420 | $2,800,622.50 | 100.0%