Electronically Filed
`Apr 11 2025 11:55 AM
`Elizabeth A. Brown
`Clerk of Supreme Court
`
`ATTACHMENTS TO
`DOCKETING STATEMENT
`
`PART 2
`
`Docket 90001 Document 2025-16398
`
`

`

`Electronically Filed
`12/1/2022 4:01 PM
`Steven D. Grierson
`CLERK OF THE COURT
`
`TRAVIS E. SHETLER, ESQ.
`Nevada Bar No. 4747
`travis@shetlerlawfirm.com
`LAW OFFICES OF TRAVIS E. SHETLER
`3202 W. Charleston Boulevard
`Las Vegas, Nevada 89102
`(702) 931-9700 - Telephone
`(702) 931-9800 - Facsimile
`Attorney for Plaintiff
`
`DISTRICT COURT
`CLARK COUNTY, NEVADA
`
`CASE NO.: A-19-797292-C
`DEPT. NO.: 5
`
`HEARING REQUESTED
`Hearing Date: 12/20/2022
`Hearing Time: 9:30 a.m.
`
`TAMARA VASEY, individually and as
`Special Administrator of the Estate of
`DELAND SIDNEY VASEY, Deceased,
`Plaintiff,
`
` vs.
`
`FEDEX GROUND PACKAGE SYSTEM
`INC.; F E D E X C O R P R O A T I O N ; G
`H G CORPORATION; RAFAEL
`ACEVEDO-CASILLAS and DOE
`EMPLOYEES 1 through X; ROE
`CORPORATIONS I through X; inclusive
`Defendants.
`
`
`
`PLAINTIFF’S REPLY TO
`PRIOR COUNSEL’S [OPPOSITION MISNAMED AS A REPLY TO COUNSEL’S
`MOTION TO ADJUDICATE THE RIGHTS OF PRIOR COUNSEL & FOR A JUDICIAL
`DETERMINATION OF FORMER COUNSEL’s ATTORNEY’S LIEN
`
`NOTICE is hereby given by the undersigned attorney, Travis E. Shetler, Esq. of the LAW OFFICE
`OF TRAVIS E. SHETLER, hereby files Plaintiff’s Reply to Prior Counsel’s [Opposition
`Misnamed as a Reply] to Counsel’s Motion to Adjudicate the Rights of Prior Counsel & for a
`Judicial Determination of Former Counsel’s Attorney’s Lien.
`. . .
`. . .
`. . .
`
`Page 1 of 11
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`Case Number: A-19-797292-C
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`Las Vegas, Nevada 89102
`
`3202 W. Charleston Boulevard
`TRAVIS E. SHETLER
`
`Law Office Of
`
`

`

`The Respondent is entitled to the following monies:
`
`Attorney fees are billed at $ 33,900.00 and should be:
`
`$ 22,600.00.
`
`Respondent has billed his staff at an alleged fair market rate. In fact, Respondent is only
`entitled to his actual costs for his employees services. He can not make money off of his clients for
`what he could contract out his staff for.
`$ 26,893.00.
`Staff fees are billed at $ 1,044,942.50 and should be billed at
`Respondent has billed $22,307.31 in costs for Deland Vasey when in actuality it
`$ 10,697.21
`should be no more than
`Respondent has billed $29,892.40 in costs for Tamara Vasey when in actuality it
`$ 26,060.27
`should be no more than
`
`Respondent’s Lien should actually be
`
`$ 86,250.48
`
`The Opposition filed by the Defendant clearly illustrates the weaknesses in the claimed lien.
`The Respondent admits that he “guessed” at the original lien amount , $907,199.00 (See Exhibit 1)
`and has now increased the lien by nearly 30% to $1,164,942.21. Respondent falsely claimed that time
`was of the essence when he filed the original lien. In fact, the undersigned immediately notified the
`Respondent that the lien would be honored. Acknowledgment of the lien was communicated
`simultaneously with the notice of termination. Instead, the Respondent filed a grossly inflated “lien”
`casing the client great concern and worry.
`In fact, both of the claimed “liens” are specious. The current “lien” consists of 2083 entries.
`Of those, only 2005 billed entries predated the client’s termination of Respondent. This makes any
`billing entry after September 2020 suspect. These appear to be charges generated solely to create this
`“lien.” One example of this is the 95 hours blocked-billed for PZ from 9/23/22 - 11/10/22.
`Furthermore, any charges generated after termination are solely the responsibility of the Respondent
`and cannot be collected from a “client” whom the Respondent no longer represented.
`
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`
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`The Respondent’s cavalier handing of his claimed “liens” is further highlighted by his
`Opposition. Respondent fails to adequately address the factors set forth by the Supreme Court of
`Nevada in Brunzell v. Golden Gate Nat'l Bank. More specifically, the Respondent fails to justify his
`excessive fees, rates and costs.
`The Brunzell factors consist of:
`(1) the qualities of the advocate: his ability, his training, education, experience,
`professional standing and skill;
`(2) the character of the work to be done: its difficulty, its intricacy, its importance, time
`and skill required, the responsibility imposed and the prominence and character of the
`parties where they affect the importance of the litigation;
`(3) the work actually performed by the lawyer: the skill, time and attention given to the
`work [and];
`(4) the result: whether the attorney was successful and what benefits were derived
`
`Brunzell v. Golden Gate Nat'l Bank, 85 Nev. 345, 349, 455 P.2d 31, 33-34 (1969).
`
`Additionally, the Respondent flaunts the standards set forth in the Nevada Rule of Professional
`Conduct 1.5. NRPC 1.5 sets forth a prohibition against unreasonable fees and expenses. While there
`is some similar analysis, the factors to be considered include:
`
`
`
`
`
`(a) A lawyer shall not make an agreement for, charge, or collect an unreasonable
`fee or an unreasonable amount for expenses. The factors to be considered in
`determining the reasonableness of a fee include the following:
`(1) The time and labor required, the novelty and difficulty of the questions
`involved, and the skill requisite to perform the legal service properly;
`
`(2) The likelihood, if apparent to the client, that the acceptance of the particular
`employment will preclude other employment by the lawyer;
`
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` (3) The fee customarily charged in the locality for similar legal services;
`
` (4) The amount involved and the results obtained;
`
`(5) The time limitations imposed by the client or by the circumstances;
`
` (6) The nature and length of the professional relationship with the client;
`
`(7) The experience, reputation, and ability of the lawyer or lawyers performing
`the services; and
`
`
`
`(8) Whether the fee is fixed or contingent.
`
`Specifically, the Respondent’s claimed fees and costs must be reduced from their artificially
`inflated figures for the following reasons:
`
`1 –
`
`The Respondent claims an excessive hourly fee for his services. While an
`hourly rate of seven hundred and fifty dollars ($750.00) per hour is cited, the
`undersigned posits that the highest hourly fee claimed by a personal injury
`attorney in Southern Nevada should be more in the neighborhood of five
`hundred dollars ($500.00) per hour.
`
`Applying this reduction to the Respondent’s lien reduces his legal fees for his
`services from a claimed $ 33,900.00 to a still high figure of $ 22,600.00.
`
`2 –
`
`The Respondent claims an excessive hourly fee for his employees. Respondent
`
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`attempts to bill attorneys and staff as the southern Nevada market rate. In fact,
`the Respondent should only be allowed to claim his actual wages and salaries
`paid to the employees, not an alleged and artificially created “fair market rate”
`for said services. Mary Chopski was an employee of Respondent’s firm for
`over a decade. Her job duties were that of office manager and legal assistant.
`Ms. Chopski is familiar with the salaries and wages paid to employees of the
`Respondent’s firm. The Declaration of Mary Chopski, attached hereto as
`Exhibit 2, sets forth the hourly rate for each employee at the time of the
`Respondent’s “Bill” for their services.
`Those rates are set forth as follows:
`TES
`$55.00
`KB
`$40.00
`MAK $55.00
`AG
`$40.00
`SAM $55.00
`CJD $55.00
`CS
`$37.50
`PZ
`$32.00
`MC
`$39.00
`DB
`$22.00
`BB
`$20.00
`FB
`$25.00
`
`This means that the amount billed by Respondent for said services should be modified as
`follows:
`
`AG, billed incorrectly at $750/hour, actually was paid at roughly $40.00/hour.
`This takes the charges for 4.5 hours from $ 3,375.00 down to
`(See Exhibit 3)
`$ 180.00.
`
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`TS, billed incorrectly at $750/hour, actually was paid at roughly $55.00/hour.
`This takes the charges for 1202 hours from $901,500.00 down to 343.50 hours
`(See Exhibit 4)
`$18,772.50.
`
`MAK, billed incorrectly at $750/hour, actually was paid at roughly
`$55.00/hour. This takes the charges for 176.3 hours from $132,225.00 down
`to 11.8 hours
`(See Exhibit 5)
`
`$ 649.00.
`
`KB, billed incorrectly at $750/hour, actually was paid at roughly $40.00/hour.
`This takes the charges for 12.2 hours from $ 9,150.00 down to
`(See Exhibit 3)
`$ 488.00.
`
`SAM, billed incorrectly at $750/hour, actually was paid at roughly
`$55.00/hour. This takes the charges for .1 hours from $ 75.00 down to
`(See Exhibit 3)
`$ 5.50.
`
`CJD, billed incorrectly at $125/hour, actually was paid at roughly $55.00/hour.
`This takes the charges for 1.9 hours from $ 237.50 down to
`(See Exhibit 3)
`
`$ 104.50.
`
`CS, billed incorrectly at $125/hour, actually was paid at roughly $37.50/hour.
`This takes the charges for .2 hours from $ 25.00 down to
`(See Exhibit 3)
`
`$ 7.50.
`
`PZ, billed incorrectly at $125/hour, actually was paid at roughly $30.00/hour.
`This takes the charges for 300 hours from $ 37,500.00 down to 185 hours
`(See Exhibit 6)
`$ 5,920.00.
`
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`AP, billed incorrectly at $125/hour, actually was paid at roughly $30.00/hour.
`This takes the charges for .2 hours from $ 25.00 down to
`(See Exhibit 3)
`
`$ 6.00.
`
`CCC, billed incorrectly at $125/hour, actually was paid at roughly $30.00/hour.
`This takes the charges for .1 hours from $ 12.50 down to
`(See Exhibit 3)
`
`$ 3.00.
`
`MC, billed incorrectly at $50/hour, actually was paid at roughly $39.00/hour.
`This takes the charges for 17.4 hours from $ 870.00 down to
`(See Exhibit 3)
`$ 678.00.
`
`DB, billed incorrectly at $50/hour, actually was paid at roughly $25.00/hour.
`This takes the charges for 0.6 hours from $ 30.00 down to
`(See Exhibit 3)
`
`$ 15.00.
`
`BB, billed incorrectly at $50/hour, actually was paid at roughly $20.00/hour.
`This takes the charges for .1 hours from $ 5.00 down to
`(See Exhibit 3)
`
`$ 2.00.
`
`DG, billed incorrectly at $50/hour, actually was paid at roughly $25.00/hour.
`This takes the charges for .1 hours from $ 5.00 down to
`(See Exhibit 3)
`
`$ 2.50.
`
`CPD, billed incorrectly at $50/hour, actually was paid at roughly $20.00/hour.
`This takes the charges for .4 hours from $ 20.00 down to
`(See Exhibit 3)
`
`$ 8.00.
`
`Page 7 of 11
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`FB, billed incorrectly at $50/hour, actually was paid at roughly $25.00/hour.
`This takes the charges for 2.1 hours from $ 105.00 down to
`(See Exhibit 3)
`
`$ 52.00.
`
`THE RESPONDENT HAS FRAUDULENTLY BILLED THE CLIENT FOR
`985 HOURS $738,750.00 – OVER 65% OF HIS CURRENT CLAIMED LIEN
`The Respondent has fraudulently and artificially padded his claimed lien. Perhaps the most
`glaring evidence of this fact is his claim that the client must pay for round the clock travel (24 hours
`per calendar day). Not only did he fraudulently bill 24 hours for each day (for individuals who were
`paid on a salary for 8 hour days), but the Respondent is asking this court to force the client to pay for
`travel and training that was completely unrelated to her file. (See Declaration of Mindy Bish, Esq.
`attached hereto as Exhibit 7 as well as Exhibits 4 & 5).
`Respondent is entitled to be compensated for that travel which was related to the client’s file.
`The reality is, this is only a small fraction of what was fraudulently claimed. Although he requested
`a total of 144 hours for attorney travel, the actual hours attorneys spent traveling on behalf of the client
`is 70.5 Although this was billed at $750 per hour, it is the undersigned position that these hours may
`only be reimbursed at the hourly rate the Respondent paid the attorneys. That hourly rate is
`approximately $55 per hour. (See Exhibits 2, 4 & 5)
`The Respondent has billed my client 12 hours for PZ to travel to Tonopah on 8/12/20, when
`in fact the undersigned made this trip alone. Also billed to my client is 95 hours to prepare the
`Respondent lien for dates of service from 9/23/22 - 11/10/22. This billing seeks monies from my
`client after the Respondent was no longer representing her and therefore should be denied.
`Respondent has billed four separate Focus groups (at four different figures) for a total charge
`of $5,521.50. Respondent has also submitted attorney fees for focus groups consisting of twenty-
`seven hours of MAK at the rate of $ 750 per hour and the undersigned for twenty-seven (27) hours
`at $750.00. In reality, the undersigned conducted the focus groups and is therefore intimately familiar
`with the financial details of same.
`This Honorable Court should only find that my client is responsible for the actual monies the
`
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`

`

`Respondent spent and the wages paid. This reduces the billed amount of $40,500.00 to $1,320.00.
`Furthermore, the undersigned made sure the four separate cases were presented to each focus group.
`Therefore, the client can only be made to pay for her proportionate charges, or 25% of the properly
`billed amount ($1,320.00) which reduces the client’s share of fees to $330.00. Additionally, the
`Respondent has billed Focus Groups expenses to $5,521.50.
`Again, the client should only be responsible for 25% of these charges which equals $1,380.38, as the
`remaining expenses should be borne by the other clients presented in the focus groups.
`The Respondent has billed Deland Vasey for Westlaw research (“People Map research”) in
`the amount of $ 350.00 and Tamara Vasey $350.00. In reality, the Respondent had a fixed plan for
`Westlaw. It inconceivable that a cost billed to the client of $350.00 is accurate when there is a flat fee
`paid to Westlaw which is likely no more than $150 per month.
`The Respondent has billed Deland Vasey $450.00 for “Clear Search” which is fee paid to
`Thomas Reuters. This is also a fixed plan of no more than $150 per month.
`The Respondent has billed Tamara Vasey $1,856.00 for Westlaw research on 8/11/2020. No
`other information is provided as to additional dates, topics or issues researched. Furthermore, there
`is no Westlaw billing number provided. Once again, this is a fixed plan of no more than $150 per
`month. Without any of the specifics listed above, there is no way for the Respondent to collect any of
`these charges from my client.
`The Respondent has billed Deland Vasey $1,400.00 for“4 Case Conferences/Expert Institute”.
`The Respondent provides no information whatsoever. No dates, details, names, or any other relevant
`information is provided to identify what this alleged charge is based on.
`Lastly, the postage and fax charges are clearly fictitious numbers cited to artificially inflate the
`monies the Respondent is attempting to collect from the client. Copy and scan and fax charges are
`claimed in the amount of $2,116.93 for Deland Vasey, who died in the collision and had no medical
`records to copy. Respondent’s copy charges for Tamara Vasey are $627.63. There is no page count,
`job reference or any other means of identifying the validity or necessity of said charges. Certainly,
`any copies made by the Respondent related to duplicating the file for his own records are not the
`client’s responsibility. Additionally, the Respondent’s claimed copy charges are wildly
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`Page 9 of 11
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`

`

`disproportionate. Although the Respondent claims over $2,000 in copy charges against Deland Vasey
`file, he seeks less than a third of that figure ($627.63) from the Tamara Vasey file. This is
`unexplainable as her file includes tens of thousands of pages of medical records in contrast to the lack
`of any medical records for her deceased husband.
`CONCLUSION
`Based upon the foregoing, Plaintiff respectfully request that this Court reduce the Respondent’s
`Lien to the extent said lien complies with the Brunzell factors as well as NRPC 1.5. Specifically, it
`is requested that this Honorable Court issue an Order granting Respondent a lien in the amount of
`$86,250.48 Additionally, it is respectfully requested that the Respondent bear the attorney’s fees
`incurred in fighting to resolve the distorted and deceitful liens and pleadings filed by the Respondent.
`DATED this 1st day of December, 2022.
`
`
`
`LAW OFFICES OF TRAVIS E. SHETLER
`/s/ Travis Shetler
`By:
` Travis E. Shetler, Esq.
` Nevada Bar No. 4747
` travis@shetlerlawfirm.com
` 3202 W. Charleston Boulevard
` Las Vegas, Nevada 89102
` Attorney for Plaintiff
`
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`Page 10 of 11
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`

`

`CERTIFICATE OF SERVICE
`
`Pursuant to Nevada Rules of Civil Procedure 5(b), the amendment to the Eighth Judicial
`District Court Rule 7.26, and N.E.F.C.R. 9, I hereby certify that service of the foregoing
`PLAINTIFF’S REPLY TO PRIOR COUNSEL’S REPLY TO COUNSEL’S MOTION TO
`ADJUDICATE THE RIGHTS OF PRIOR COUNSEL & FOR A JUDICIAL
`DETERMINATION OF FORMER COUNSEL’s ATTORNEY’S LIEN was made this date by
`electronic service via the Court’s electronic filing and service system, addressed to the following:
`
`Steven M. Burris, Esq.
`STEVEN M. BURRIS, LLC
`2810 W. Charleston Blvd., Suite F58
`Las Vegas, Nevada 89102
`Telephone: (702) 258-6238
`Facsimile: (702) 258-8280
`
`Michael J. Nunez, Esq.
`Murchison & Cumming LLP
`350 South Rampart Boulevard, Suite 320
`Las Vegas, Nevada 89145
`Attorney for Defendants,
`FedEx Ground Systems
`
`M. Bradley Johnson, Esq.
`Kravitz, Schnitzer & Johnson, CHTD.
`8985 S. Eastern Ave., Suite 200
`Las Vegas, Nevada 89123
`Attorneys for Defendant,
`Rafael Acevedo-Casillas
`
`Michael C. Mills, Esq.
`Bauman Lowew Witt & Maxwell
`3650 N. Rancho Dr., Suite114
`Las Vegas, Nevada 89130
`Attorneys for Defendant,
`GHG Corporation
`
`Stacey R. Cutting, Esq.
`Devin A. Cutting, Esq.
`Bish & Cutting, APC
`22505 Market Street, Suite 104
`Newhall, CA 91321-2935
`
`Mindy Susan Bish, Esq.
`Keenan Law Firm
`148 Nassau St. NW
`Atlanta, GA 30303
`Attorney for Plaintiffs Tamara Vasey
`and the Estate of Deland Sidney Vasey
`Appearing Pro Hac Vice
`
`DATED this 1st day of December, 2022.
`
`
`
`
`
`/s/ Lori Ann Puma
`______________________________________
`An Employee of Law Office of Travis E. Shetler
`
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`Page 11 of 11
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`

`

`ATTACHMENT 1
`ATTACHMENT 1
`
`ATTACHMENT 1
`ATTACHMENT 1
`
`

`

`STEVEN M. BURRIS
`ANDREW J. THOMAS
`KEVIN BOYLE
`GARY MYERS
`
`BURRIS & THOMAS
`A Limited Liability Corporation
`2810 W. CHARLESTON BOULEVARD
`SUITE F-58
`LAS VEGAS, NEVADA 89102
`
`AREA CODE(702)
`TELEPHONE 258-6238
`FAX 258-8280
`
`January 28, 2022
`
`Michael C, Mills, Esq.
`Bernadette A. Rigo, Esq.
`Buaman Loewe Witte & Maxwell
`3650 N. Rancho Drive, Suite 114
`Las Vegas, Nevada 89130
`
`‘Tamara Vasey
`2341 Vista Grand Drive
`Vista, California 92084
`
`Via Certified Mail
`
`Travis E. Shetler, Esq.
`Law Office of Travis E. Shetler, PC
`3202 W. Charleston Blvd.
`Las Vegas, Nevada 89102
`
`Michael J. Nunez, Esq.
`Murchison & Cumming LLP
`350 South Rampart Boulevard, Suite 320
`Las Vegas, Nevada 89145
`
`M.Bradley Johnson, Esq.
`Kravitz Schnitzer & Johnson, Chtd.
`$985 S. Eastern Ave., Suite 200
`Las Vegas, Nevada 89123
`
`RE:
`
`Vasey v. FedEx Ground Package System, Inc., et. al
`Case No.: A-19-797292-C
`
`Dear Colleagues and Ms, Vasey:
`
`Please be advised that my claimed lien on the above-referenced cases for fees and costs, notice of
`which was previously given, and claims is for $855,000 in fees and costs of $52,199.71, or total
`$907,199. As the work performed related to both the estate and individual claims, the lien pertains to
`the claims of both; however, it is a global lien, i.e. we are not asking this amount to be paid twice.
`
`Very truly yours,
`
`BURRIS & THOMAS, LLC
`
`/s/ Steven M, Burris
`
`Steven M. Burris, Esq.
`
`

`

`ATTACHMENT 2
`ATTACHMENT 2
`
`ATTACHMENT 2
`ATTACHMENT 2
`
`

`

`EXHIBIT 1
`EXHIBIT 1
`
`EXHIBIT 1
`EXHIBIT 1
`
`

`

`DECLARATION OF
`
`MARY CHOPSKI
`
`COMESNOW,MARY CHOPSKI,whoherebystates under penalty ofperjury:
`
`1.
`
`2.
`
`2:
`
`Mynameis Mary Chopski
`
`I am over eighteen yearsold.
`
`I am a residentof the State of Nevada and I am of sound mind and body.
`
`I was employed by Steven Burris, Esq. as a Legal Assistant with office management
`duties from October 2010 to July 2021.
`
`SoeHNNDBWNBf
`
`In this capacity I was intimately familiar with and have a working knowledgeofthe
`salaries and wagespaid by Steven Burris to his employeesat the timeIleft.
`
`Specifically, It is my belief and understanding that the hourly rate paid to each
`employee is approximately as follows:
`
`TES
`KB
`AG
`CJD
`PZ
`CS
`SL
`MC
`SR
`NG
`DB
`JA
`JB
`CD
`
`$55.00
`$40.00
`$40.00
`$55.00
`$32.00
`$37.50
`$37.50
`$39.00
`$30.00
`$30.00
`$22.00
`$22.00
`$20.00
`$20.00
`
`The aboveis declared by me, under
`Nevada,to betrue andcorrect, signedthis 1
`
`penalty of the perjury laws, lawsin the State of
`1" day of November, 2022.
`
`c
`
`Mary“eS
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`Z3
`
`24
`
`25
`
`26
`
`27
`
`28
`
`Page 1 of 1
`
`

`

`ATTACHMENT 3
`ATTACHMENT 3
`
`ATTACHMENT 3
`ATTACHMENT 3
`
`

`

`Employee Hours Billed
`
`AG
`
`AP
`
`BB
`
`CS
`
`CJD
`
`CCC
`
`CPD
`
`DB
`
`DG
`
`4.5
`
`.2
`
`.1
`
`.2
`
`1.9
`
`.1
`
`.4
`
`.6
`
`.1
`
`STAFF HOURS AND BILLABLE RATE
`Claimed Rate
`Total Charged
`APPROXIMATE
` Per Hour Billed
`Based on
`Actual Hourly
`Claimed Rate of
`Rate OF Pay Per
`Pay
`Hour
`$40.00
`$3,375.00
`
`$750.00 p/h
`
`$125.00 p/h
`
`$50.00 p/h
`
`$125.00 p/h
`
`$25.00
`
`$5.00
`
`$25.00
`
`$125.00 p/h
`
`$237.50
`
`$125.00 p/h
`
`$50.00 p/h
`
`$50.00 p/h
`
`$50.00 p/h
`
`$12.50
`
`$20.00
`
`$30.00
`
`$5.00
`
`$30.00
`
`$20.00
`
`$37.50
`
`$55.00
`
`$30.00
`
`$20.00
`
`$25.00
`
`$25.00
`
`Actual billable
`hours
`
`4.5
`
`.2
`
`.1
`
`.2
`
`1.9
`
`.1
`
`.4
`
`.6
`
`.1
`
`Total
`Allowable
`Charges
`
`$180.00
`
`$6.00
`
`$2.00
`
`$7.50
`
`$104.50
`
`$3.00
`
`$8.00
`
`$15.00
`
`$2.50
`
`

`

`FB
`
`KB
`
`MJC
`
`SAM
`
`2.1
`
`12.2
`
`17.4
`
`.1
`
`$50.00 p/h
`
`$105.00
`
`$750.00 p/h
`
`$9,150.00
`
`$50.00 p/h
`
`$750.00 p/h
`
`$870.00
`
`$75.00
`
`$25.00
`
`$40.00
`
`$39.00
`
`$55.00
`
`2.1
`
`12.2
`
`17.4
`
`.1
`
`$52.00
`
`$488.00
`
`$678.00
`
`$5.50
`
`Total billed $13,935.00 @ “Market Rate”
`Total allowable $1,552.00
`
`TOTAL BILLABLE STAFF
`
`$1552.00
`
`

`

`ATTACHMENT 4
`ATTACHMENT 4
`
`ATTACHMENT 4
`ATTACHMENT 4
`
`

`

`Employee
`
`Hours Billed
`
`Hour Per Hour
`Billed
`
`Total Charged
`By Burris
`
`APPROXIMATE
`Real Hourly Pay
`
`Accurate
`billable
`hours
`
`Total
`Allowable
`Charges
`
`TES
`
`1202
`
`$750.00 p/h
`
`$901,500.00
`
`$55p/h
`
`343.50
`
`$18,772.00
`
`UNDISPUTED HOURS BILLED
`
`210 Uncontested Hours billed at $750 p/h – should only be at $55 p/h – $11,577.50
`
`DISPUTED CHARGES
`
`991.50 Hours Billed at $750 p/h – should only be 129.9 Hours at $55 p/h – $7,144.50
`
`INCORRECT
`HOURS
`BILLED
`
`DESCRIPTION OF BILLED HOURS
`
`Correct
`Charges
`
`REASON
`
`144
`
`8
`
`8
`3
`
`Prepare and attend Keenan Training (2/12/19 - 2/17/19)
`
`Focus Group
`
`Focus Group
`Focus Group
`
`0
`
`2
`
`2
`2
`
`NOT RELATED
`KEENEN DID NOT TAKE THE CASE UNTIL MARCH 2019
`SO THIS HAD NOTHING TO DO WITH VASEY CASE
`
`Focus groups were approximately 6-8 hours long
`and covered four different cases. Client should
`only be charged 25% (2 hours)
`
`Focus groups were approximately 6-8 hours long
`and covered four different cases. Client should
`only be charged 25% (2 hours)
`
`DATE
`
`2/12/19
`
`3/20/19
`
`3/26/19
`
`3/27/19
`
`

`

`3/28/19
`
`4/27/19
`
`7/18/19
`
`8/23/19
`8/27/19
`
`8
`
`6
`
`2
`
`12
`3
`
`Focus Group
`
`Prepare and attend Focus Group at Adam Ganz's office w/
`Keenan
`
`Prep for and conduct teleconference w/Keenan and Bish
`
`Travel to Tonopah and back to Las Vegas
`Prepare and attend Keenan Class w/ David Bernstein
`
`8/27/19
`
`120
`
`Prepare and attend Keenan Edge Class (8/27/19 - 8/31/19)
`
`10/24/19
`2/12/20
`
`2/19/20
`
`2/28/20
`3/10/20
`
`14
`2.5
`
`120
`
`12
`144
`
`Prep, Travel and meet with Tammie Vasey in California
`Review Smith System Drive Different Driver Study
`Guide
`Attend Keenan Workshop (2/19/20 - 2/23/20)
`
`Travel to Tonopah and back to Las Vegas
`Keenan Workshop 3/10/20 - 3/14/20
`
`4/23/20
`
`4
`
`Prepare and attend Keenan Focus Group Zoom Meetings
`
`2
`
`0
`
`.4
`
`8
`0
`
`0
`
`8
`1
`
`.5
`
`8
`16
`
`0
`
`Focus groups were approximately 6-8 hours long
`and covered four different cases. Client should
`only be charged 25% (2 hours)
`NOT RELATED
`I never attended this
`Video Conference lasted no longer than 20
`minutes
`I am only paid for 8 hours a day
`NOT RELATED
`THIS WAS TRAINING TO BE AN INSTRUCTOR
`NOTHING TO DO WITH VASEY
`
`NOT RELATED
`THESE WERE GENERAL COLLEGE COURSES
`NOT RELATED TO VASEY
`
`I am only paid for 8 hours a day
`At max I spent an hour reviewing this guide
`
`NO WORKSHOP. I HAD A VC WITH MINDY ON 2/20
`FOR 30 MINS ON VASEY
`
` I am only paid for 8 hours a day
`WORKSHOP WAS THE 12TH & 13TH. THE WORKSHOP
`LASTED 8 HRS EACH DAY AND WAS ONLY 2 DAYS
`
`NOT RELATED
`THIS WAS TO BE AN INSTRUCTOR NOT VASEY
`
`

`

`4/29/20
`
`5/6/20
`
`5/8/20
`5/12/20
`5/13/20
`
`5/18/20
`5/19/20
`
`4
`
`5
`
`10
`8
`120
`
`12
`120
`
`Prepare and attend Keenan Zoom Meeting
`
`Research and draft OPP to Def Mtn for Mand Settlement
`Conf
`Prepare and attend conference code training with Keenan
`Prepare and attend Keenan Code Training
`Prepare and attend Keenan Workshop (5/13/20 - 5/18/20)
`
`0
`
`2
`
`8
`8
`0
`
`Travel to and from California for meeting with Vasey
`Prep for and attend Keenan Workshop (5/19/20 -5/23/20)
`
`8
`14
`
`6/23/20
`
`14
`
`Prep and attend Keenan Workshop
`
`7/3/20
`
`8/5/20
`
`8/12/20
`8/13/20
`8/20/20
`
`4
`
`4
`
`12
`8
`12
`
`Focus Group
`
`Prep and attend keenan Hit List Workshop.
`
`Travel to Tonopah and back to Las Vegas
`Draft Opposition to Defendants’ Mtn for Protective Order
`Prepare and attend Keenan Root Cause Analysis
`Workshop
`
`8
`
`2
`
`3
`
`8
`3
`0
`
`NOT RELATED
`KTI FACULTY MEETING NOT RELATED TO VASEY
`
`NOT RELATED
`THAT WAS PREMISES WORKSHOP NOT TRACTOR
`TRAILER - NOT RELATED
`
`I am only paid for 8 hours a day
`THIS WAS A ZOOM WORKSHOP
`TWO DAYS ONLY MAY 20 AND 21
`7 HOURS EACH DAY.
`
`ZOOM 1 DAY TRAINING 8 HOURS
`
`Focus groups were approximately 6-8 hours long
`and covered four different cases. Client should
`only be charged 25% (2 hours)
`ZOOM THIS WAS 3 HOURS
`
`I am only paid for 8 hours
`
`NOT RELATED
`THIS WAS Med Mal workshop ONLY
`
`

`

`8/21/20
`
`8/22/20
`
`8/27/20
`
`12
`
`12
`
`24
`
`Prepare and attend Keenan Root Cause Analysis
`Workshop
`
`Prepare and attend Keenan Root Cause Analysis
`Workshop
`
`0
`
`0
`
`NOT RELATED
`THIS WAS Med Mal workshop ONLY
`
`NOT RELATED
`THIS WAS Med Mal workshop ONLY
`
`Travel to Tonopah and Back (8/27/20 - 8/28/20)
`
`16
`
`Can only bill for 8 hours a day
`
`Total 29.9
`
`

`

`ATTACHMENT 5
`ATTACHMENT 5
`
`ATTACHMENT 5
`ATTACHMENT 5
`
`

`

`Employee
`
`Hours Billed
`
`Claimed Rate
` Per Hour Billed
`
`MAK
`
`176.3
`
`$750.00 p/h
`
`Total Charged
`Based on
`Claimed Rate of
`Pay
`$132,225.00
`
`APPROXIMATE
`Actual Hourly
`Rate OF Pay Per
`Hour
`$55p/h
`
`Actual billable
`hours
`
`Total
`Allowable
`Charges
`
`11.8
`
`$649.00
`
`UNDISPUTED HOURS BILLED
`
`3.3 Uncontested Hours billed at $750 p/h – should only be at $55 p/h – $181.50
`
`DISPUTED CHARGES
`
`173 Hours Billed at $750 p/h – should only be 8.5 Hours at $55 p/h – $467.50
`
`DESCRIPTION OF BILLED HOURS
`
`Actual
`Hours
`
`REASON
`
`Prepare and attend Keenan Training (2/12/19 - 2/17/19)
`
`Focus Group
`
`Focus Group
`
`Focus Group
`
`0
`
`2
`
`2
`
`2
`
`KEENAN DID NOT TAKE THE CASE UNTIL MARCH 2019 SO
`THIS HAD NOTHING TO DO WITH VASEY
`
`Focus groups were approximately 6-8 hours long and
`covered four different cases. Client should only be
`charged 25% (2 hours)
`
`Focus groups were approximately 6-8 hours long and
`covered four different cases. Client should only be
`charged 25% (2 hours)
`
`Focus groups were approximately 6-8 hours long and
`covered four different cases. Client should only be
`charged 25% (2 hours)
`
`DATE CLAIMED
`HOURS
`BILLED
`
`2/12/19
`
`3/22/19
`
`3/26/19
`
`3/27/19
`
`144
`
`8
`
`8
`
`3
`
`

`

`3/28/19
`
`7/18/19
`
`8
`
`2
`
`Focus Group
`
`Prep for and conduct teleconference w/Keenan and Bish
`
`2
`
`.4
`
`Focus groups were approximately 6-8 hours long and
`covered four different cases. Client should only be
`charged 25% (2 hours)
`
`Video Conference lasted no longer than 20 minutes
`
`

`

`ATTACHMENT 6
`ATTACHMENT 6
`
`ATTACHMENT 6
`ATTACHMENT 6
`
`

`

`Employee
`
`Hours Billed
`
`Claimed Rate
` Per Hour Billed
`
`PZ
`
`300
`
`$120.00 p/h
`
`Total Charged
`Based on
`Claimed Rate of
`Pay
`$37,500.00
`
`APPROXIMATE
`Actual Hourly
`Rate OF Pay Per
`Hour
`$32.00 p/h
`
`Actual billable
`hours
`
`Total
`Allowable
`Charges
`
`185
`
`$5,920.00
`
`UNDISPUTED HOURS BILLED
`
`169 Uncontested Hours billed at $125 p/h – should only be at $32 p/h – $5,408.00
`
`DISPUTED CHARGES
`
`131 Hours Billed at $125 p/h – should only be 16 Hours at $32 p/h – $512.00
`
`DATE CLAIMED
`HOURS
`BILLED
`12
`12
`12
`95
`
`8/23/19
`2/28/20
`8/12/20
`9/23/20
`
`DESCRIPTION OF BILLED HOURS
`
`Travel to Tonopah and back to Las Vegas
`Travel to Tonopah and back to Las Vegas
`Travel to Tonopah and back to Las Vegas
`Prepare Lien (9/23/22 - 11/10/22)
`
`Actual
`Hours
`
`8
`8
`0
`0
`
`REASON
`
`PZ paid for a 8 hour work day
`PZ paid for a 8 hour work day
`PZ did not attend this trip
`Work performed post termination
`
`

`

`ATTACHMENT 7
`ATTACHMENT 7
`
`ATTACHMENT 7
`ATTACHMENT 7
`
`

`

`DECLARATION OF MINDY BISH, ESQ.
`
`1.
`I, Mindy Bish, Esq., declare under penalty of Nevada’s perjury laws, that the following
`is true and correct.
`2.
`I have personal knowledge of the following facts except as stated upon information and
`belief and, as for those facts, I, in good faith, believe them to be true.
`3.
`I am an attorney at Keenan Law Firm, Associate Dean at The Keenan Trial Institute
`and represent Plaintiffs in this lawsuit as co-counsel.
`4.
`I have cross-checked the following training dates with The Keenan Trial Institute
`and can confirm the following:
`
`2/12/19 - 2/17/19
`
`–
`
`–
`
`–
`
`–
`
`–
`
`–
`
`–
`
`–
`
`–
`
`–
`
`–
`
`1 2 3 4 5 6 7 8 9
`
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`3202 W. Charleston Boulevard
`TRAVIS E. SHETLER
`
`Las Vegas, Nevada 89102
`
`Law Office Of
`
`8/27/19 - 8/31/19
`
`2/19/20 - 2/23/20
`
`3/10/20 - 3/14/20
`
`Prepare and attend Kennan Training
`WE DID NOT TAKE THE CASE UNTIL MARCH 2019
`SO THIS HAD NOTHING TO DO WITH VASEY
`7/18/2019 Prep for and conduct teleconference w/ Keenan and Bish.
`MY VIDEO CONFERENCES LASTS 20 MINS MAX
`8/27/2019 Prepare and attend Keenan Class w/ David Bernstein.
`
`THIS WAS TRAINING TO BE AN INSTRUCTOR
`NOTHING TO DO WITH VASEY
`Prepare and attend Keenan Edge Class
`THESE WERE GENERAL COLLEGE COURSES NOT
`RELATED TO VASEY
`Attend Keenan Workshop
`NO WORKSHOP. I HAD A VIDEO CONFERENCE
`WITH TRAVIS ON 2/20 FOR 30 MINS ON VASEY
`Keenan Workshop
`WORKSHOP WAS THE 12 AND 13.... THE
`WORKSHOP LASTED 8 HRS EACH DAY AND WAS
`ONLY 2 DAYS
`4/23/2020 Prepare and attend Keenan Focus Group Zoom Meetings.
`THIS WAS TO BE AN INSTRUCTOR NOT VASEY
`4/29/2020 Prepare and attend Keenan zoom meeting.
`KTI FACULTY MEETING NOT RELATED TO
`VASEY
`5/8/2020 Prepare and attend Conference Code Training w/ Keenan.
`CODES TRAINING - 10 HOURS
`5/12/2020 Prepare and attend Keenan Code Training.
`TRACTOR TRAILER CODE TRAINING 8 HOUR
`
`5/13/20 - 5/18/20
`
`Prepare and attend Keenan Workshop
`
`Page 1 of 2
`
`DocuSign Envelope ID: 8F1D5731-8092-4330-9970-175C750498EE
`
`

`

`THAT WAS PREMISES WORKSHOP NOT
`TRACTOR TRAILER
`
`–
`
`5/19/20 - 5/23/20
`
`Prep for and attend Keenan workshop
`THERE WAS NO HOMEWORK AND THIS WAS A
`ZOOM WORKSHOP
` 2 DAYS MAY 20 AND 21 - 7 HOURS EACH DAY
`
`–
`
`–
`
`–
`
`–
`
`–
`
`6/23/2020 Prep and attend Keenan Workshop.
`ZOOM 1 DAY TRAINING 8 HOURS
`8/5/2020 Prep and attend Keenan Hit List Workshop.
`ZOOM THIS WAS 3 HOURS
`
`8/20/2020 Prepare and attend Keenan Root Cause Anaylsis Workshop.
`THIS WAS MEDICAL MALPRACTICE WORKSHOP
`- NOT VASEY RELATED
`8/21/2020 Prepare and attend Keenan Root Cause Anaylsis Workshop.
`THIS WAS MEDICAL MALPRACTICE WORKSHOP
`- NOT VASEY RELATED
`8/22/2020 Prepare and attend Keenan Root Cause Anaylsis Workshop.
`THIS WAS MEDICAL MALPRACTICE WORKSHOP
`- NOT VASEY RELATED
`
`The above is declared by me, under penalty of Nevada’s perjury laws, to be true and
`5.
`correct to the best of my information and belief.
`
`DATED this ______ day of November, 2022.
`
`________________________________________
`MINDY BISH, ESQ.
`
`1 2 3 4 5 6 7 8 9
`
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`Page 2 of 2
`
`DocuSign Envelope ID: 8F1D5731-8092-4330-9970-175C750498EE
`
`30
`
`

`

`INTENTIONALLY
`INTENTIONALLY
`LEFT BLANK
`LEFT BLANK
`
`

`

`Electronically Filed
`12/5/202