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Attorney Client Privilege

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

WHO WILL COMPLETE

HOURS

MPV

10

JLS JLS JLS

2 8 2

JLS

September 30, 2011

st

JLS/MPV

November 30, 2011

st

JLS/MPV JLS/MPV JLS/MPV JLS/MPV JLS/MPV JLS/MPV JLS/MPV JLS/MPV JLS/MPV

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

November 30, 2011

JLS/MPV JLS/MPV

November 30, 2011 November 30, 2011

4 2

Attorney Client Privilege


TARGET DATE OF COMPLETION November 30, 2011 Stip./Motion to Ext. Discovery if Needed Must be Returnable by Dec. 16, 2011 N/A at this time. COST BUDGETED

ACTIVITY Attend Other Witness Deposition as determined through discovery

WHO WILL COMPLETE

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

{identify responsible attorney}/ {identify responsible attorney}/ JLS/MPV

Samuels, Azariah Eshkenazi and Leanard Zaretski


Attention to Correspondence Mediation & Settlement Negotiations Preparation of Interim Status Reports Travel, Lodging & Other Expenses Prepare Chronology Binders Preparation of Motion for Summary Judgment Preparation of Reply Brief Prepare/Attend Oral Argument Trial Preparation/Final Pretrial Order Trial Post-Trial Motions No Experts Designated No Expert Depositions No Fictitious Defendants Revealed TOTAL

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

Ongoing August 31, 2011 Ongoing

10 2 2 N/A

Ongoing as Discovery Proceeds 12/25/11 (DED)

TBD

Summary Litigation Plan BCPO