EFiled: May 03 2024 04:18PNEDT
`Transaction ID 72884947 (Fa i}
`Case No. Multi-Case
`RRa)
`
`OF peer
`
`
`
`
`EXHIBIT B
`EXHIBIT B
`
`
`
`EFiled: May 03 2024 04:18PM EDT
`Transaction ID 72884947
`Case No. Multi-Case
`
`
`Transaction ID 72884947 (Fa i}
`Case No. Multi-Case
`RRa)
`
`OF peer
`
`
`
`
`EXHIBIT B
`EXHIBIT B
`
`
`
`EFiled: May 03 2024 04:18PM EDT
`Transaction ID 72884947
`Case No. Multi-Case
`
`
`
`IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
`
`In re: TRANSPERFECT GLOBAL, INC.
`
`C.A. No. 9700-CM
`
`ELIZABETH ELTING,
`Petitioner,
`
`V.
`
`PHILIPR. SHAWE and SHIRLEY SHAWE.
`Objectors,
`
`and
`
`TRANSPERFECT GLOBAL, INC.,
`Nominal Party.
`
`C.A. No. 10449-CM
`
`AFFIDAVIT OF CHARLES DAVANT
`
`I am a partner in the law firm Williams & Connolly LLP ("W&C"), which
`1.
`represents Robert Pincus, who served as Custodian for the Court of Chancery of the State of
`Delaware. This declaration is based on my personal knowledge and the billing records of W&C,
`which are kept in the ordinary course of business.
`
`The hours worked and billed, hourly rates, timekeepers' positions, tasks performed,
`2.
`and total fees and out-of-pocket expenses for W&C for Mr. Pincus for the months of January and
`February 2024 are set forth in the invoices attached as Exhibits 1-2, which I have reviewed. These
`amounts were actually incurred and, in my judgment, were reasonable for the tasks that were
`performed. W&C did not issue an invoice for the month of March 2024.
`
`The hourly rates charged by W&C in the attached invoices are consistent with the
`3.
`hourly rates charged by W&C to clients other than Mr. Pincus.
`
`Washington, D.C.:
`Signed and swom to before me on Friday, April 5, 2024, byCharles pavant IV, who is known to
`
`me.
`
`Charles Davant IV
`
`AELAR.
`
`C eLUNS
`
`ON
`EXP.
`2-14-28
`
`OiSTRICAS
`
`Notary Public
`
`ANA C. MELARA
`NOTARY PUBLIC DISTRICT OF COLUMBIA
`My Commission Expires February 14, 2028
`
`
`
`February 8, 2024
`
`PRIVILEGED AND CONFIDENTIAL
`
`Robert B. Pincus
`Court-Appointed Custodian
`PO Box 4570
`Wilmington, DE 19807
`
`Matter Description: TransPerfect v Pincus Case 1:22-cv-01477
`
`BILLING STATEMENT
`
`Professional Services Rendered thru January 31, 2024
`
`TOTAL PROFESSIONAL FEES
`
`TOTAL EXPENSES
`
`Exhibit 1
`
`Invoice Number: 561327
`
`$61,577.50)
`
`$61,577.50)
`
`($1,096.18))
`
`CURRENT FEES AND EXPENSES DUE……………………………………………….
`
`$60,481.32)
`
`Balance Due From Previous Statement
`
`PRIOR BALANCE DUE
`
`$447,298.84)
`
`$447,298.84)
`
`TOTAL BALANCE DUE AS OF THIS DATE…………………………………………
`
`$507,780.16)
`
`
`
`CLIENT NO. 47094
`INVOICE NO. 561327
`February 8, 2024
`
`Matter No. 47094.0004 – TransPerfect v Pincus Case 1:22-cv-01477
`
`TITLE
`Partner
`Associate
`Counsel
`
`TIMEKEEPER SUMMARY
`
`HOURS
`7.70
`19.70
`24.80
`52.20
`
`RATE
`1,425.00
`970.00
`1,270.00
`
`AMOUNT
`10,972.50
`19,109.00
`31,496.00
`$61,577.50
`
`Date
`
`Timekeeper
`
`Narrative
`
`Hours
`
`01/04/24
`
`Associate
`
`01/04/24
`
`Partner
`
`01/04/24
`
`01/05/24
`
`01/05/24
`
`01/05/24
`
`01/08/24
`
`01/09/24
`
`01/09/24
`
`01/10/24
`
`01/10/24
`
`01/11/24
`
`Counsel
`
`Counsel
`
`Associate
`
`Partner
`
`Counsel
`
`Counsel
`
`Associate
`
`Associate
`
`Counsel
`
`Associate
`
`01/11/24
`
`Partner
`
`01/11/24
`
`Partner
`
`Research points raised in TPH's motion for injunctive
`relief and composed findings re: same.
`
`Attention to Transperfect Holdings’ federal motion for
`injunction.
`
`Draft response to motion for injunctive relief.
`
`Draft response to motion for injunctive relief.
`
`Reviewed transcript from Chancery fee petition hearing
`for purpose of federal action.
`
`Attention to federal filings.
`
`Work on opposition to motion for injunction.
`
`Work on opposition to motion for injunctive relief.
`
`Legal research re: possible application of res judicata to
`federal motion for injunction.
`
`Research re: applicability of the All Writs Act.
`
`Work on opposition to motion for injunctive relief.
`
`Call with Credit Suisse counsel re: judicial assignment
`and Holdings' letter to federal court re: same.
`
`Commn’s w/ colleagues re: Transperfect Holdings letter
`to court re: reassignment of federal court case to Judge
`Hall.
`
`Attention to draft response to Holdings’ motion for
`injunction.
`
`01/11/24
`
`Counsel
`
`Draft opposition to motion for injunctive relief.
`
`4.90
`
`1.70
`
`3.50
`
`0.90
`
`0.30
`
`0.50
`
`1.20
`
`4.50
`
`2.20
`
`3.60
`
`4.00
`
`0.20
`
`0.20
`
`2.80
`
`4.00
`
`Page 2
`
`Amount
`
`4,753.00
`
`2,422.50
`
`4,445.00
`
`1,143.00
`
`291.00
`
`712.50
`
`1,524.00
`
`5,715.00
`
`2,134.00
`
`3,492.00
`
`5,080.00
`
`194.00
`
`285.00
`
`3,990.00
`
`5,080.00
`
`
`
`CLIENT NO. 47094
`INVOICE NO. 561327
`February 8, 2024
`
`Matter No. 47094.0004 – TransPerfect v Pincus Case 1:22-cv-01477
`
`Date
`
`Timekeeper
`
`Narrative
`
`Hours
`
`01/11/24
`
`Counsel
`
`01/11/24
`
`Associate
`
`01/12/24
`
`Associate
`
`01/12/24
`
`01/12/24
`
`Partner
`
`Counsel
`
`01/15/24
`
`Partner
`
`01/15/24
`
`01/16/24
`
`01/16/24
`
`01/17/24
`
`01/17/24
`
`01/24/24
`
`01/24/24
`
`01/24/24
`
`Counsel
`
`Partner
`
`Counsel
`
`Partner
`
`Counsel
`
`Partner
`
`Partner
`
`Counsel
`
`Call with Credit Suisse counsel re: letter from Plaintiff
`and draft email re: same.
`
`Drafted All Writs Act argument and added caselaw
`citations for same.
`
`Further work on brief opposing injunction and filling in
`citations.
`
`Work on opposition to preliminary injunction motion.
`
`Drafting work for opposition to motion for injunctive
`relief.
`
`Attention to draft opposition to Plaintiff’s injunction
`motion.
`
`Review proposed edits to opposition.
`
`Attention to response to federal injunction motion.
`
`Work on opposition to motion for injunction.
`
`Work re: opposition to injunction motion.
`
`Work on opposition to motion for injunction.
`
`Considered email from Mr. Noyes.
`
`Attempted meet-and-confer with Mr. Noyes.
`
`Read Reply brief supporting injunction.
`
`0.30
`
`2.50
`
`6.00
`
`1.40
`
`3.00
`
`0.20
`
`0.30
`
`0.20
`
`1.50
`
`0.40
`
`1.30
`
`0.20
`
`0.10
`
`0.30
`
`Page 3
`
`Amount
`
`381.00
`
`2,425.00
`
`5,820.00
`
`1,995.00
`
`3,810.00
`
`285.00
`
`381.00
`
`285.00
`
`1,905.00
`
`570.00
`
`1,651.00
`
`285.00
`
`142.50
`
`381.00
`
`TOTAL PROFESSIONAL SERVICES:
`
`$61,577.50
`
`
`
`Page 4
`
`CLIENT NO. 47094
`INVOICE NO. 561327
`February 8, 2024
`
`Matter No. 47094.0004 – TransPerfect v Pincus Case 1:22-cv-01477
`
`EXPENSE DESCRIPTION
`CCRED (Cash Receipt / Negative Disbursement)
`
`EXPENSE SUMMARY
`
`Total Expenses Due:
`
`DESCRIPTION
`
`01/08/2024
`
`WILLIAMS,
`KRISTINA
`
`TRANSPERFECT TRANSLATIONS
`INTERNATIONAL, INC.
`
`Total Expenses:
`
`AMOUNT
`-1,096.18
`
`($1,096.18)
`
`-1,096.18
`
`($1,096.18)
`
`
`
`REMITTANCE PAGE
`
`Client Name:
`Matter Number:
`Invoice Number:
`Invoice Date:
`Billing Attorney:
`
`Pincus, Robert B.
`47094.0004
`561327
`February 8, 2024
`John Villa
`
`Matter Description: TransPerfect v Pincus Case 1:22-cv-01477
`
`Note: Payment is due within 30 days from the date of this invoice
`
`CURRENT FEES AND EXPENSES DUE
`PRIOR BALANCE DUE
`TOTAL BALANCE DUE AS OF THIS DATE………………………………………….
`
`$60,481.32
`$447,298.84
`$507,780.16
`
`FOR WIRE OR ACH TRANSFERS OF FUNDS INTO OUR ACCOUNT:
`
`Beneficiary Bank:
`ABA Routing #:
`Account #:
`
`For Wire Transfers
`Bank of America
`026009593
`001918423668
`
`For ACH Transfers
`Bank of America
`054001204
`001918423668
`
`Williams & Connolly LLP International Swift Code: BOFAUS3N
`Bank of America Reference Address: 222 Broadway, New York, NY 10038
`Please provide the invoice number(s), client name and matter number(s) being paid
`
`Remittance Email Address: AccountsReceivable@wc.com
`Tax ID: 52-0851221
`
`IF YOU WISH TO PAY BY CHECK, PLEASE REMIT TO THE ADDRESS BELOW*:
`
`US Mailing Address
`Williams & Connolly LLP
`Chicago Lockbox
`P.O. Box 7410903
`Chicago, IL 60674-0903
`
`Overnight Mailing Address
`Williams & Connolly LLP
`Chicago Lockbox 10903
`540 W. Madison, 4th Floor
`Chicago, IL 60661
`
`*All payments should be made payable to: Williams & Connolly LLP.
`
`TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email
`
`
`
`(cid:40)(cid:91)(cid:75)(cid:76)(cid:69)(cid:76)(cid:87)(cid:3)(cid:21)
`
`Invoice Number: 562630
`
`March 12, 2024
`
`PRIVILEGED AND CONFIDENTIAL
`
`Robert B. Pincus
`Court-Appointed Custodian
`PO Box 4570
`Wilmington, DE 19807
`
`Matter Description: TransPerfect v Pincus Case 1:22-cv-01477
`
`BILLING STATEMENT
`
`Professional Services Rendered thru February 29, 2024
`
`TOTAL PROFESSIONAL FEES
`
`$9,405.00)
`
`$9,405.00)
`
`CURRENT FEES AND EXPENSES DUE……………………………………………….
`
`$9,405.00)
`
`Balance Due From Previous Statement
`
`PRIOR BALANCE DUE
`
`$507,780.16)
`
`$507,780.16)
`
`TOTAL BALANCE DUE AS OF THIS DATE…………………………………………
`
`$517,185.16)
`
`
`
`CLIENT NO. 47094
`INVOICE NO. 562630
`March 12, 2024
`
`Matter No. 47094.0004 – TransPerfect v Pincus Case 1:22-cv-01477
`
`Page 2
`
`TIMEKEEPER SUMMARY
`
`HOURS
`6.60
`6.60
`
`RATE
`1,425.00
`
`AMOUNT
`9,405.00
`$9,405.00
`
`Timekeeper
`
`Narrative
`
`Hours
`
`Amount
`
`Read TPH's motion for recusal.
`
`Read legal authorities cited by TPH, plus additional
`cases.
`
`Outlined possible response to TPH's motion.
`
`Communication with co-counsel re sme.
`
`Communication with Credit Suisse's counsel re same.
`
`Drafting response to TPH’s motion to recuse.
`
`Commn’s w/ CS counsel and co-counsel re: TPH’s
`motion to recuse.
`
`Further work on draft response to TPH's motion for
`reassignment/recusal.
`
`Read CS filing in response to TPH’s motion for recusal
`and other follow-up.
`
`Read TPG Court of Chancery filings concerning
`pending federal action.
`
`Call w/ co-counsel re: recent TPG and TPH filings of
`relevance to federal action.
`
`Read and commented upon draft filing pertinent to
`requests for relief in federal action.
`
`0.10
`
`0.60
`
`0.40
`
`0.20
`
`0.10
`
`2.60
`
`0.50
`
`0.70
`
`0.10
`
`0.40
`
`0.60
`
`0.30
`
`142.50
`
`855.00
`
`570.00
`
`285.00
`
`142.50
`
`3,705.00
`
`712.50
`
`997.50
`
`142.50
`
`570.00
`
`855.00
`
`427.50
`
`TOTAL PROFESSIONAL SERVICES:
`
`$9,405.00
`
`TITLE
`Partner
`
`Date
`
`02/03/24
`
`02/03/24
`
`02/03/24
`
`02/03/24
`
`02/03/24
`
`02/04/24
`
`02/04/24
`
`Partner
`
`Partner
`
`Partner
`
`Partner
`
`Partner
`
`Partner
`
`Partner
`
`02/05/24
`
`Partner
`
`02/06/24
`
`Partner
`
`02/14/24
`
`Partner
`
`02/15/24
`
`Partner
`
`02/28/24
`
`Partner
`
`
`
`REMITTANCE PAGE
`
`Client Name:
`Matter Number:
`Invoice Number:
`Invoice Date:
`Billing Attorney:
`
`Pincus, Robert B.
`47094.0004
`562630
`March 12, 2024
`John Villa
`
`Matter Description: TransPerfect v Pincus Case 1:22-cv-01477
`
`Note: Payment is due within 30 days from the date of this invoice
`
`CURRENT FEES AND EXPENSES DUE
`PRIOR BALANCE DUE
`TOTAL BALANCE DUE AS OF THIS DATE………………………………………….
`
`$9,405.00
`$507,780.16
`$517,185.16
`
`FOR WIRE OR ACH TRANSFERS OF FUNDS INTO OUR ACCOUNT:
`
`Beneficiary Bank:
`ABA Routing #:
`Account #:
`
`For Wire Transfers
`Bank of America
`026009593
`001918423668
`
`For ACH Transfers
`Bank of America
`054001204
`001918423668
`
`Williams & Connolly LLP International Swift Code: BOFAUS3N
`Bank of America Reference Address: 222 Broadway, New York, NY 10038
`Please provide the invoice number(s), client name and matter number(s) being paid
`
`Remittance Email Address: AccountsReceivable@wc.com
`Tax ID: 52-0851221
`
`IF YOU WISH TO PAY BY CHECK, PLEASE REMIT TO THE ADDRESS BELOW*:
`
`US Mailing Address
`Williams & Connolly LLP
`Chicago Lockbox
`P.O. Box 7410903
`Chicago, IL 60674-0903
`
`Overnight Mailing Address
`Williams & Connolly LLP
`Chicago Lockbox 10903
`540 W. Madison, 4th Floor
`Chicago, IL 60661
`
`*All payments should be made payable to: Williams & Connolly LLP.
`
`TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email
`
`
`
`Multi-Case Filing Detail: The document above has been filed
`and/or served into multiple cases, see the details below including
`the case number and name.
`
`Transaction Details
`
`Court: DE Court of Chancery Civil Action Document Type: Exhibits
`Document Title: Exhibit B - Invoices of
`Williams & Connolly LLP for the Period of
`January – March 2024
`Submitted Date & Time: May 3 2024 4:18PM
`
`Transaction ID: 72884947
`
`Case Details
`
`Case Number
`9700-CM
`10449-CM
`
`Case Name
`CONF ORD ON DISC In re TransPerfect Global Inc
`CONF ORD/Elting, Elizabeth vs Philip R Shawe et al
`
`
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