SMITH BAKKE PORSBORG SCHWEIGERT Phone Number: 701-258-0630 P.O. Box 460, 116 North Second Street Bismarck, ND 58502-0460 Federal Tax ID, No. 45-0448023 Tag C. Anderson, Risk Management Division 1600 East Century Avenue, Suite 4 Bismarck, ND 58503-0649 April 01, 2010 RE: James Long v. State of North Dakota, Workforce Safety and Insurance, Charles "Sandy" Blunt, John Halvorson, Tim Wahlin, Rob Forward, Tag Anderson, Robert Indvik, and Mark Gjovig Hows _ Amount 02/25/10 RIB Review email from Tag Anderson re: motion 0.10 in limine and related issues. 02/27/10 RIB Follow up re: completion of motion in 0.20 limine and review and reply to memo re: same: RJB Prepare and revise jury instructions and 0.70 special verdict form. 03/0110 MDA. 1c w/AA[/——irrrrrreres 0.80 MDA. Worked on motion in limine brief 140 MDA. TC w/ court and opposing counsel re: trial 0.60 issues and email to clients re: same; reviewed response emails fom clients MDA Prepared for and me! 1.10 MDA TC w/ Jodi Bjomson re: witness interviews 0.40Tag C. Anderson 03/01/10 MDA. TC w/Tag re: witnesses contacted; 1. MDA Meeting QI RIB RIB Ls Ls Review and reply to email re: Long's expert witness issues, Review lengthy email re: Judge Goodman conference and reply email re: trial handling issues. Ticonf with witness Ls LS Ls JA Drafting letter to University of Mary requesting plaintiff's employment records. Drafting letter to University of Mary requesting plaintifi’s employment records. Ticonf with, Compile exhibits for motion in limine. Page Hours __Amount 0.20 0.20 0.90 0.10 0.20 0.60 0.20 0.10 0.20 0.20 0.20 0.50Tag C. Anderson Page 3 Hours __Amount | 03/01/10 JA "Telephone conference with Judge Goodman 0.10 | re: hearing on motion in limine. JA Prepare filing cover letter for motion in 0.10 limine, 03/02/10 MDA Mecting Quam 0.90 LS Drafting subpoena duces tecum to 0.40 | KBRRVJim Shaw re: news story and i interview of plaintiff. | LS Tieonf with —= 0.20 | 03/03/10 MDA. Review deposition of Billi Peltz re: trial 0.50 preparation issues DA 1 TS on MDA Reviewed jury instructions and conference 0.80 ww/ RIB re: same and trial issues; email to clients re: jury instructions MDA. TC wi Jodi Bjornson re: witness interviews, 0.40 follow up regarding same, further handling and trial issues MDA Worked on exhibit list for trial 0.50 MDA Meeting Se ed MDA Reviewed and considered email from Tag. 1.50 Anderson re: jury instructions; revised jury instructions re: same; TC w/ Tag re: hisTag C. Anderson Page 4 Hours __Amount | email; revised verdict form re: same; conference w/ RIB re: verdict form changes per conversation w/ Tag 03/03/10 MDA Meeting ama 1.10 MDA TC w/ Barnes County Clerk re: jury 0.20 questionnaire MDA Worked on witness list 0.50 RIB _ Further preparation of jury instructions. 020 RIB Staff'conference with Mitch re: trial 030 preparation issues and re: handling issues. RIB Staff conference re: jury verdict form and 0.30 related issues and follow up re: same. LS Receipt and review of email from attorney 0.10 re: additional interviews. | LS — Tieonfs with witnesses; 0.20 : LS Teall to witness, 0.10 LS Communicate with attorney re: witness 0.10 LS Tcalls to locate witnesses A 0.20Tag C. Anderson 03/03/10 LS Research and sai to locate 03/04/10 MDA. Add to witness list MDA Conf. w/ LSS re: additional witness MDA Review subpoena to Jim Shaw re: interview of Jim Long MDA TC w/ Tag re: Shaw subpoena, LSS at trial, and Long expert disclosure MDA. Continued reviewing exhibits for trial and adding to exhibit list 03/05/10 RIB Lengthy conference with Mitch re: trial preparation issues including handling of witnesses. LS Conf with attorney re: trial preparation and attendance, LS Review plaintiff's discovery answers regarding dates of employment with Contact America. LS Email communications wi _ LS Ticonf with, Hours __Amount 0.30 0.20 0.20 0.10 0.10 7.00 0.60 0.30 0.10 0.20 0.20Tag C. Anderson Page 6 Hours __Amount 03/05/10 LS 8 =S lle 0.10 LS Begin preparation of trial exhibits. 1.00 MDA Continued working on exhibits and exhibit 1.10 list MDA Conference w/ RIB re: dividing witnesses at 0.70 trial and voir dire, opening, and closing; email to clients re: same MDA Conference w/ LSS re: further items to 030 follow up on re: exhibit list and witnesses MDA TC w/Tag Anderson re: trial issues 0.70 MDA Review email from Doug Bab re: jury 0.10 instructions and verdict form and make changes re: same MDA Meeting va: 1.30 MDA Worked on juror questionnaire 0.50 MDA Teleconference w/ clients MDA Tc vi 0.30 03/06/10 RIB Review correspondence from clerk of district 0.10 court and follow up re: same. fitness list 0.30 RIB Staff conference re: pretrial conference 0.10 preparation issues. MDA Draft jury questionnaire 3.30Tag C. Anderson 03/06/10 MDA. Letter to opposing counsel re: supplementation of Long's discovery answers re: income earned 03/07/10 RIB Review letter to legal counsel re: handling of ‘trial matters, RUB _ Review and reply to email re: trial preparation issues. 03/08/10 LS T/call to witness LS Receipt and review of plaintiff's employment, records from University of Mary. LS Receipt and review of plaintiff's employment records from Cross Country Courier. LS Conf with attorney re: additional witness terviews off LS T/conf with Jim Shaw re: subpoena for Feb 2008 news story. LS Preparation continued on exhibit list and trial exhibits. LS __ Preparation continued on exhibit list and trial exhibits. MDA Reviewed information for Grinsteinner depo and prepare for deposition Page 7 Hours _Amount 0.10 0.10 0.20 0.10 0.20 0.20 0.20 0.20 2.70 4.50 6.50Tag C. Anderson 03/08/10 MDA. MDA MDA 03/09/10 RIB RIB MDA MDA MDA MDA MDA MDA 03/10/10 LS. Review additional potential exhibits and add to exhibit list Prepare for and mect with JIS Reviewed, Staff conference re: trial continuance issues. Prepare and revise jury questionnaire. Continued preparing for Kay Grinsteinner deposition and prepare questions for Grinsteinner TC w/ opposing counsel re: trial issues and he will be filing a motion for extension of time and settlement ‘TC w/ Tag Anderson re: phone conversation ‘w/ opposing counsel TC w/ John Halvorson re: Grinsteinner depo TC w/ Tim Wablin re: Grinsteinner depo Reviewed email and brief from opposing counsel re: continuance of trial and email to clients re: same; e-mail to court re: same; reviewed email from court and reply to same; follow up re: continuance issues Preparation continued on trial exhibits and 0.20 0.60 6.00 0.20 0.20 0.20 0.20 0.80 2.30Tag C. Anderson 03/10/10 LS Ls Ls MDA MDA MDA 03/11/10 RIB MDA MDA MDA MDA MDA Receipt and review of plaintiff's Motion for Extension of Time for Trial, ‘Ticonf with witness ‘Tieall to, Add to defendant's witness list for trial. Final preparation for and attend deposition of Kay Grinsteinner ‘TC w/ Tag re: deposition and further handling Reviewed emails provided by Tim Wahlin yesterday Staff conference with Mitch re: pretrial conference and trial postponement issues and trial preparation issues. Reviewed document provided by Tuntland Meeting at Risk Management re: records ‘TC from John Halvorson Reviewed additional documentation received from Risk Management ‘Teleconference w/ Court and opposing counsel; follow up TC w/ opposing counsel; email to clients re: teleconference; reviewed Page 9 Hours __Amount 0.10 0.10 0.10 0.30 5.90 0.10 0.20 0.20 0.20 0.80 0.20 2.30 0.80Tag C. Anderson, Page 10 | | ——Hours unt email from opposing counsel's office and proposed orders 03/11/10 MDA. Revised jury questionnaire and email to 0.40 opposing counsel re: same MDA Revise Witness and Exhibit List 0.60 | 03/12/10 MDA Mectng 0.90 03/15/10 RIB Staff conference re: pretrial conference 0.20 issues and trial issues. MDA. Draft pre-trial statement and revise exhibit 1.40 list MDA Reviewed orders signed by court and email 0.10 to clients re: same LS Reciept and review of email correspondence 0.20 regarding trial continuance; and drafting | email to client WSLre:_contact information for witness | 03/16/10 MDA. TC w/ Jodi Bjornson re: status update 030 LS 0.30 LS Add to witness and exhibits lists for tial, 030 LS Add to defendant's exhibit list and witness 1.80 list for trial to attach to pretrial statement. 03/17/10 RIB Staff conference re: pretrial conference 0.20 issues.Tag C. Anderson 03/17/10 MDA. Revised pretrial statement and exhibit list MDA Conference w/ RIB re: pre-trial filings MDA TC w/ opposing counsel re: pretrial conference issues MDA TC w/Tag Anderson 03/18/10 RIB Prepare and revise defendant's witness list. RIB Prepare and revise defendant's exhibit list. MDA Review and respond to email from Tag Anderson re: open records request MDA Email to clients re: exhibit list, MDA Final revisions to exhibit and witness list MDA TC w/ John and Jodi re: exhibit and witness list MDA Review and respond to email from Tag Anderson on trial preparation issues MDA Reviewed Long's reply brief to motion in Jimine and began drafting reply 03/19/10 MDA. TC w/ Sonja Nallie MDA. Finalized pre-trial filings Page 11 Hours __Amount 2.20 0.20 0.30 0.20 0.50 0.10 0.30 0.20 0.10 0.30 0.30 0.40 1.40 0.50 0.40Tag C. Anderson 03/19/10 MDA RIB 03/20/10 MDA. RIB RIB 03/21/10 MDA RIB RB RIB 03/22/10 RIB Worked on reply to Long's response to motion in limine Staff conference with Mitch re: pretrial conference issues, Continued working on reply brief'in support of motion in limine Review memo re: exhibit list and witness list issues and re: exhibits to use for Long's cross ‘examination. Review correspondence to client re: pretrial conference issues. Review emails status reports including ‘Tuntiand’s witness list and follow up re: same, Add to reply brief in support of motion in imine per RIB's comments and revisions Review email re: reply brief issues on motion in limine. Review Long's reply to motion in limine and prepare and revise reply brief in support of motion in limine. Staff conference re: pretrial conference issues and strategy for same Prepare and revise defendant's pretrial statement, Page 12 Hours __Amount 3.60 0.20 5.20 0.20 0.10 0.20 0.50 0.10 0.90 0.20 0.20Tag C. Anderson 03/22/10 MDA MDA 03/23/10 MDA. 03/24/10 RIB MDA MDA MDA 03/25/10 MDA 03/26/10 RIB 03/29/10 MDA 03/31/10 MDA LS Reviewed and incorporated changes into brief as requested by clients and TC w/ Tag Anderson re: same; final revisions to Tesponse to motion in limine ‘TC from Jodi Bjornson re: response to motion in limine Reviewed applicable rules and case law for pre-trial hearing on motions in limine Prepare for motion in limine and pretrial conference and attend pretrial conference and post pretrial conference re: further handling. Prepare for and attend pre-trial hearing, Review and revise scheduling order sent by plaintiffs counsel Email to clients re: new trial dates and deadlines, TC w/ Doug Bahr re: plaintift's witness list Review notes re: pretrial conference issues by judge and follow up re: handling of same. Reviewed letter from Tag Anderson Review of signed scheduling order Receipt and review of instructions from attorney re: contact with witnesses and rescheduled trial 1.70 0.10 1.20 2.40 0.10 0.10 0.10 0.10 0.10 0.10 Page 13 jount,Tag C. Anderson. Page 14 03/31/10 LS T/calls and communications with 16 0.60 witnesses re: rescheduled trial, LS Receipt and review of March 2010 0.10 | Scheduling Order. For professional services rendered © 118.10 $13,728.50 | Additional charges: 02/28/10 Westlaw research 132.22 03/05/10 KBRR-TV - Witness Fee for subpoena 25.00 (03/08/10 Barnes County Clerk of Court - Copies of Jury Questionaire 705 Lisa Hulm Reporting, Inc. - Depositions of Billi Peltz 437.20 University of Mary - Copies of Records for Jim Long 4.65 Cross Country Courier - Copies of Records for Jim Long, 9.20 03/18/10 Photocopies 219.60 04/01/10 Lisa Hulm Reporting, Inc. - Deposition of Kay Grinsteinner 656.90 Total costs $1,492.52 Total amount of this bill $15,221.02 Previous balance $13,549.23, 3/5/2010 Payment - Thank You ($13,549.23) Total payments and adjustments ($13,549.23)Tag C. Anderson Page 15 Amoun| Balance due $15,221.02 Attomey Summary Name Hours ___Rate __Amount | Jackie Andahl (JA) Paralegal 0.70 85.00 $59.50 | Lori Steckler (L8) Paralegal 20.20 85.00 ‘$1,717.00 i Mitchell D. Armstrong (MDA) Attomey 87.60 120.00 $10,512.00 Randall J. Bakke (RIB) Attorney 9.60 150.00 $1,440.00