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ESTIMATED LITIGATION PLAN & BUDGET for REPRESENTATION OF BCPO New Jersey Superior Court, Docket No.: BER-L-9266-10
The following Litigation Plan and Budget is an estimate of fees that will be incurred in relation to the tasks that we will need to perform in the defense of this action. Naturally, certain activities may not take place (e.g., discovery motions), and the progression of the litigation may require activities that are currently unanticipated. This document is merely intended to provide a rough outline of the work to be performed and the estimated time for completion of each anticipated task.
TARGET DATE OF COMPLETION July 12, 2011 (extended date) (Post mediation) September 9, 2011 September 16, 2011 September 30, 2011 COST BUDGETED
ACTIVITY Prepare and Serve Paper Discovery/Respond to Paper Discovery from adversaries Prepare for Plaintiff Lucia Kui Deposition Attend Plaintiffs Lucia Kui Deposition Prepare for BCPO Deposition (to be named Prosecutor Molinelli) Attend BCPP Deposition (to be named - Prosecutor Molinelli) Prepare for Det. 1 Grade Jin Sun Kim Deposition (Card key incident) Attend Det. 1 Grade Jin Sun Kim Deposition Prepare for Sgt. Therese Steele Deposition (dress code violation) Attend Sgt. Therese Steele Deposition Prepare for Chief Roger Kane Deposition (supposed racist comments by Kelleher) Attend Dr. Chief Roger Kane Deposition Prepare for Lt. Paul Cardone Deposition (Pls removal of firearms) Attend Lt. Paul Cardone Deposition Prepare for Sgt. Anthony Gentle Deposition (Toaster oven incident) Attend Sgt. Anthony Gentle Deposition Prepare for Capt. John Palotta Deposition (retaliation faced by Pl. following objections to BCPO rules & regs) Attend Capt. John Palotta Deposition Prepare for Other Witness Deposition
Summary Litigation Plan BCPO
HOURS
MPV
10
2 8 2
JLS
st
JLS/MPV
st
November 30, 2011 November 30, 2011 November 30, 2011 November 30, 2011 November 30, 2011 November 30, 2011 November 30, 2011 November 30, 2011 November 30, 2011
4 2 4 2 4 2 4 2 4
JLS/MPV
JLS/MPV JLS/MPV
4 2
HOURS
JLS/MPV
10???
Discovery Motions
JLS/MPV
Protective Order Compliance Electronic Discovery Management/Analysis Prepare for Deposition of Physician(s) Attend Deposition of Plaintiffs Physician(s) 4 Physicians Drs. Jane Harris, Stephanie
JLS/MPV
12/25/11 (DED)
16
JLS/MPV JLS/MPV JLS/MPV {identify responsible attorney} MPV JLS/MPV JLS/MPV JLS/MPV JLS/MPV JLS/MPV JLS/MPV
10 2 2 N/A
TBD