T210 Bond and/or Detention Hearing
Time spent attending bond hearing. Time spent preparing presentation for bond hearing, including meeting with client family, identifying potential assets, creating bond package, and securing assets for corporate surety bond. Time spent researching issues related to detention. Time spent drafting motion for bond.
T220 Discovery Motions
Time spent researching and drafting motion to suppress evidence. Time spent researching and drafting motion to compel. Prepare witnesses to testify at hearing on motion to suppress. Time spent preparing cross examination of agent at motion to suppress hearing
T221 Motions to Dismiss
Time analyzing indictment and identifying potential defects. Time spent researching and drafting motion to dismiss.
T222 Motions in Limine
Time spent researching and drafting motions in limine.
T223 Other Motions
Time spent researching and drafting any other motion.
T230 Attendance at hearings
Time spent in court for any hearing not previously described.
T240 Fact Investigation
Time spent interviewing potential witnesses. Time spent inspecting client's business. Time spent reviewing client documents. Time spent identifying potential defense exhibits.
T250 Electronic Discovery
Time spent creating electronic database containing government discovery and any relevant client documents. Time spent creating search terms to use in reviewing electronic discovery. Time spent reviewing electronic discovery.
Inspection of Documents in law enforcement possession Time spent at law enforcement warehouses reviewing documents.
T270 Witness Preparation
Time spent preparing witnesses to testify for trial.
T271 Expert Witness Preparation
Time spent identifying potential experts. Time spent interviewing experts. Time spent with experts to understand analysis. Time spent preparing experts to testify. Time spent with experts creating exhibits.
T280 Plea Negotiations
Time spent negotiating a plea agreement. Time spent researching and calculating sentencing guidelines. Time spent discussing plea agreement with client. Time spent reviewing plea agreement. Time spent negotiating terms in plea agreement.
T281 Debriefings with Government Pursuant to Cooperation
Time spent preparing client to cooperate. Time spent in debriefings with client and Government.
T290 Trial Preparation
Time spent analyzing facts and developing defense theories. Time spent identifying potential trial witnesses. TIme spent developing direct examinations. Time spent developing cross examinations. Time spent drafting opening statement.
T291 Trial Briefs
Time spent drafting internal trial memorandum. Time spent drafting trial brief for the court.
T292 Jury Instructions
Time spent researching jury instructions. Time spent drafting jury instructions. Time spent reviewing Government's jury instructions.
Time spent in court while in trial.
T320 Trial preparation
Time spent preparing witnesses to testify. Time spent preparing cross examinations. Time spent preparing for trial. Time spent drafting closing argument. Time spent drafting trial exhibits.
Motions excluding sentencing Time spent researching and drafting post-trial motions, such as motion for judgment of acquittal.
T340 Sentencing Preparation (includes character witness preparation, client preparation, video)
Time spent preparing client to allocute at sentencing. Time spent preparing character witnesses. Time spent developing theme for sentencing. Time spent creating sentencing video. Time spent identifying and researching mitigating factors for sentencing. Time spent researching other factors for sentencing, such as loss calculations. Time spent meeting with client in preparation for interview with probation.
T350 Sentencing Memorandum
Time spent researching objections to PSR. Time spent drafting objections to PSR. Time spent drafting sentencing memorandum.
T360 Sentencing Hearing
Time spent preparing for sentencing. Time spent in court at sentencing hearing.
B410 Appellate Motions and Submissions
Time spent drafting notice of appeal. Time spent researching deadlines related to appeal. Time spent requesting trial transcript. Time spent ensuring record on appeal is correct.
B420 Bond Issues
Time spent researching and filing motion for bond pending appeal.
B430 Appellate Briefs
Time spent researching brief. Time spent drafting brief. Time spent organizing brief, exhibits, and appendix.
B440 Oral Argument
Time spent preparing for oral argument. Time spent at oral argument.