T110 Fact Gathering Time relating to gathering and researching the facts of the case. Physical collection of documents, computers, hard drives, and text messages. Meeting with client to discuss facts.
T111 Document Review Time spent reviewing client documents.
T112 Witness Interviews Time spent meeting with fact witnesses and character witnesses.
T113 Client sessions Meeting with client to discuss facts and status. Meeting with client to prepare for Government debriefing.
T120 Voluntary Disclosure/Self-Disclosure Investigation and Preparation Voluntary Disclosure/Self-Disclosure Presentation Time spent researching facts related to voluntary disclosure. Time spent with expert to determine cost of potential voluntary disclosure. Time spent drafting presentation for voluntary disclosure. Time spent preparing client for voluntary disclosure. time spent presenting voluntary disclosure to the government.
T130 Queen for a day Time spent negotiating immunity for proffer. Time spent preparing for proffer. Time spent attending client proffer.
T140 Reverse Proffer Time spent meeting with the government.
T150 Prepare client for possible searches Meeting with client and client's employees to discuss procedures in the event of search.
T160 Document retention Time spent preparing legal hold letter. Time spent implementing document retention.
T170 Search warrant Time spent at client's business during execution of search warrant. Time spent conducting inventory of documents seized during execution of search warrant.
T171 Debriefings after search warrant Time spent interviewing employees following execution of search warrant.
T180 Subpoena compliance Time spent analyzing subpoena. Time spent collecting documents in response to subpoena. Time spent reviewing documents in advance of production.
T190 Self-surrender and Bond negotiations Time spent negotiating bond. Time spent with client surrendering client. Time spent processing client at US Marshal's office.
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.
T260 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.
T310 Trial 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.
T330 Post-Trial 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.