usag notice of draw(16743081.1) - omni agent solutions

IN THE UNITED STATES BANKRUPTCY COURT FOR THE SOUTHERN DISTRICT OF INDIANA

INDIANAPOLIS DIVISION

In re: USA GYMNASTICS,1 Debtor.

Chapter 11 Case No. 18-09108-RLM-11

NOTICE OF DRAW BY DEBTOR’S COUNSEL

PLEASE TAKE NOTICE that on March 2, 2020, Barnes & Thornburg LLP, as

counsel to the debtor and debtor in possession in the above-captioned chapter 11 case,

submitted monthly invoices for fees and expenses incurred between December 6, 2018

and January 31, 2020 (Invoices)2 as provided for in the Order Granting Debtor’s

Motion For Entry Of Order establishing Procedures For Interim Compensation and

Reimbursement of Professionals [Dkt. 187] (“Interim Compensation Order”).

1 The last four digits of the Debtor’s federal tax identification number are 7871. Debtor’s principal office is located at 130 W. Washington Street, Suite 700, Indianapolis, Indiana 46204. 2 The Invoices are redacted to avoid disclosure of privileged and confidential information.

Case 18-09108-RLM-11 Doc 940 Filed 03/04/20 EOD 03/04/20 10:20:45 Pg 1 of 3

PLEASE TAKE FURTHER NOTICE that the Invoices, attached hereto as

Exhibits A through N, seek compensation for $200,679.553 in fees and $1,658.94 in

expenses.

PLEASE TAKE FURTHER NOTICE that any objections to the Invoices must

be filed and served upon the undersigned counsel by March 18, 2020 at 5:00 p.m.

(Eastern time), in accordance with the Interim Compensation Order.

PLEASE TAKE FURTHER NOTICE that, if no objection is timely filed, the

Debtor shall promptly pay 80% of the fees and 100% of the expenses identified in the

April Invoice, subject to final approval by the Court at a future hearing.

Dated: March 4, 2020 Respectfully Submitted, /s/ Mark D. Stuaan Mark D. Stuaan BARNES & THORNBURG LLP 11 South Meridian Street Indianapolis, Indiana 46204 Telephone: (317) 231-7720 Facsimile: (317) 231-7433 Email: [email protected] Counsel for Debtor, USA Gymnastics

3 $842.78 of the amount in Exhibit A, Barnes & Thornburg LLP’s January 17, 2019 invoice, was for work performed December 1-5, 2018 which was included in Barnes & Thornburg LLP’s Proof of Claim (April 29, 2019; Claim No. 334) and thus is not being included in this payment request.


CERTIFICATE OF SERVICE

I hereby certify that on March 4, 2020, a copy of the foregoing was filed electronically. Notice of this filing will be sent to parties through the Court’s Electronic Case Filing System. Parties may access this filing through the Court’s system.

I further certify that on March 4, 2020, a copy of the foregoing was electronically sent to the following:

Melissa M. Root [email protected]; [email protected] Catherine L. Steege [email protected], [email protected]; [email protected] Meredith R. Theisen [email protected], [email protected]; [email protected] James I. Stang [email protected]

/s/ Mark D. Stuaan


EXHIBIT A

Barnes & Thornburg LLP January 17, 2019 Invoice

Case 18-09108-RLM-11 Doc 940-1 Filed 03/04/20 EOD 03/04/20 10:20:45 Pg 1 of 10

BARNES & THORNBURG LLP11 South Meridian Street

Indianapolis, Indiana 46204-3535 U.S.A.E.I.N. 35-0900596

(317) 236-1313

Invoice 2187812

USA GYMNASTICSATTN: KERRY PERRY, PRESIDENT/CEO130 E. WASHINGTON ST., SUITE 700INDIANAPOLIS, IN 46204

January 17, 2019Mark D. Stuaan00075094-000001

PAYABLE UPON RECEIPT

To remit payments by check, please return this page with remittance to:

Barnes & Thornburg LLP, 11 South Meridian Street, Indianapolis, Indiana 46204-3535 U.S.A.

To remit payments by ACH or Wire, send remittance advice to [email protected] Send payment to:

Fifth Third Bank, Indianapolis, IN, Account Number: 7653510706 SWIFT CODE: FTBCUS3CABA #074908594 for ACH ABA #042000314 for Wires

We will not use email to inform you of a change in our wiring instructions

Fees for Services $ 35,374.48

Other Charges $ 0.00

TOTAL THIS INVOICE $ 35,374.48




(317) 236-1313

Invoice 2187812Page 2




00075094-000001

INVESTIGATIONS

For legal services rendered in connection with the above matter for the period ending December 31, 2018 as described on the attached detail.




00075094-000001 USA GYMNASTICS

Page 4 INVESTIGATIONS

Date Name Description Hours

12/07/18 Ladene I. Mendoza Correspondence with Casteel regarding upcoming document production; corresponded with and provided update to M. Stuaan; drafted production letter to the Indiana Attorney General's office; compiled and prepared documents for production to Indiana Attorney General's office regarding law enforcement communications.

2.00

12/09/18 Allison Scarlott Finalized draft of interrogatory response regarding the selection of the Board of Directors

0.50

12/10/18 Mark D. Stuaan Worked with L. Mendoza regarding cover letter for next production of documents to the Attorney General; telephone conversation with Edith Matthai regarding her question relating to records from the Ranch and possible production of those records to a Congressional committee.

0.20

12/10/18 Ladene I. Mendoza Drafted production letter for additional documents related to the settlement, NDA and confidentiality agreement issue tag to produce to the Indiana Attorney General's office; compiled and prepared documents for production.

1.10

12/11/18 Mark D. Stuaan Reviewed and considered the Executive Summary of the Ropes & Gray report regarding the independent investigation of USOC and USAG.

0.20

12/12/18 Patricia A. Ellis Exchanged e-mails with Landene Mendoza regarding December 10, 2018 production to Indiana Attorney General and updated production log and production table regarding same.

0.40

12/14/18 Ladene I. Mendoza Drafted cover letter regarding medical task force documents; compiled and prepared documents for production to Ind. AG's office; reviewed and finalized interrogatory charts 8, 4, and 10 before sending to CJ Schneider for review; and began reviewing and commenting on interrogatory chart 12 after Allison Scarlott's additional updated draft answers.

7.70

12/14/18 Alejandra Reichard Gathered information and updated draft responses to draft interrogatories from the Indiana Attorney General.

2.00

12/14/18 Allison Scarlott Reviewed documents regarding two individuals placed on the permanently ineligible list to determine relevant documents for production; updated interrogatory responses regarding these individuals to add more detail regarding when and how USAG became aware of allegations.

1.80

12/15/18 Ladene I. Mendoza Continued reviewing and commenting on interrogatory chart 12 regarding individual USAG members that had allegations of abuse after Allison Scarlott's updated draft answers; reviewed and analyzed misconduct folder of named individuals in interrogatories on Relativity in order to provide information requested to the Indiana Attorney General's office and drafted follow up questions to request from Mark Busby.

7.20

12/17/18 Patricia A. Ellis Updated production table and log with document production sent to Indiana Attorney General.

0.40

12/17/18 Alejandra Reichard Continued gathering information and updating draft responses for draft interrogatories from the Indiana Attorney General.

0.30





12/17/18 Allison Scarlott Continued to responses to interrogatories for Attorney General's Civil Investigative Demand.

1.30

12/18/18 Mark D. Stuaan Communications with L. Mendoza and C.J. Schneider regarding status of drafting and submitting answers to various interrogatories (Attorney General’s civil investigative demand); communication to the Deputy Attorney General regarding the same.

1.20

12/18/18 Ladene I. Mendoza Finalized draft answers to interrogatory charts 4, 8, 10, 11 after updating answers and sent to USAG personnel knowledgeable on chart topic for review and approval; reviewed and analyzed responses received from Mark McCreary and incorporated it into answers to interrogatory chart 10 regarding measures to prevent and mitigate abuse in order to finalize answers; corresponded with James Casteel

in order to provide more information in response to interrogatory inquiring about the date of first notification of allegations of misconduct; and reviewed and analyzed documents Alejandra Contreras of Miller Johnson sent in response to Interrogatories related to the Ranch in order to determine if all responsive documents were produced and provided any additional information to include in answer.

11.20

12/19/18 Mark D. Stuaan Prepared for telephone conversation with Deputy Attorney General regarding status of providing answers to interrogatories and status of revised language for certifications called for in the civil investigative demand; telephone conversation with Deputy Attorney General regarding the same; communications with C.J. Schneider following telephone conversation with Deputy Attorney General relating to the conversation and the news release issued by the Attorney General's office confirming its investigation of USAG.

0.80

12/19/18 Ladene I. Mendoza Began reviewing and analyzing misconduct documents on Relativity related to search corresponded with CJ Schneider regarding interrogatory charts status; and corresponded to Mark Stuaan regarding events that have occurred since November 9 to provide to the Indiana Attorney General's office in anticipation of teleconference.

2.80

12/20/18 Michael K. McCrory Gave attention to motion to employ B&T as special counsel to debtor; met with Mark Stuaan regarding focus of work to date and work/support requested as part of bankruptcy proceedings of USA Gymnastics; considered requirements for outside counsel engagements in connection with proposed employment.

0.90





12/20/18 Mark D. Stuaan Communications with Deputy Attorney General regarding revised language for CID certifications; communication with C.J. Schneider regarding the same; communications with Deputy Attorney General regarding answers to interrogatories and responses to requests for production; communications with L. Mendoza regarding drafts of various answers to interrogatories, and the status of producing some of the answers to the Deputy Attorney General; communications with the Deputy Attorney General regarding questions relating to Safe Sport personnel.

1.20

12/20/18 Ladene I. Mendoza Corresponded and strategized with Mark Stuaan on interrogatory chart progress, number of certifications needed for the interrogatories and producing answers to the Indiana Attorney General's office; drafted updated template for a revised certification of truth; corresponded with James Casteel on progress update for production; updated chart 10 to include answer to interrogatory number 37; and began compiling final answers from each USAG personnel from various charts into one document to send to USAG personnel for final approval before signing certification.

3.90

12/20/18 Alejandra Reichard Prepared select answered interrogatories for production to the Indiana AG's office.

2.40

12/20/18 Allison Scarlott Strategized with associate regarding content of each document containing responses to interrogatories in order to be responsive to Attorney General's demand for first set of interrogatory responses; finalized responses to interrogatories by incorporating all comments from USAG reviewers and prepared document with certification of truth to be sent to reviewer and office of Attorney General.

4.40

12/21/18 Mark D. Stuaan Communications with C.J. Schneider and Alejandra Contreras regarding draft answers to various interrogatories in the civil investigative demand; communications with L. Mendoza relating to possible assistance by Mark Busby in review of various draft answers to interrogatories and the status of draft answers of interrogatories.

1.20

12/21/18 Ladene I. Mendoza Continued compiling final answers from each USAG personnel from various charts into one document to send to USAG personnel for final approval before signing certification and producing to the Indiana Attorney General's office; drafted production letter to the Indiana Attorney General's office; compiled and produced documents regarding MSU and Larry Nassar investigation and final answer to various interrogatories to the Indiana Attorney General's office; corresponded with Mark Busby regarding status of interrogatory chart review.

4.60

12/23/18 Patricia A. Ellis Updated production log and INDAG production table of December 21, 2018 production to the Indiana Attorney General.

0.30




(317) 236-1313

Invoice 2187812












Case 18-09108-RLM-11 Doc 940-1 Filed 03/04/20 EOD 03/04/20 10:20:45 Pg 10 of10

EXHIBIT B

Barnes & Thornburg LLP February 19, 2019 Invoice




(317) 236-1313

Invoice 2197583


February 19, 2019Mark D. Stuaan00075094-000001













(317) 236-1313





00075094-000001

INVESTIGATIONS

For legal services rendered in connection with the above matter for the period ending January 31, 2019 as described on the attached detail.








01/02/19 Mark D. Stuaan Communication with C.J. Schneider relating to Fran Sepler; communication with C.J. Schneider regarding draft responses to questions from the Deputy Attorney General; considered information compiled by L. Mendoza relating to the engagement background for communications with Mark Busby regarding compilation of list of all Safe Sport complaints referred to the Center for Safe Sport by USAG in 2018, and questions related to spreadsheet compiled by USAG relating to same.

2.30

01/02/19 Patricia A. Ellis Updated production table of document production to Indiana Attorney General's Office from December 31, 2018.

0.20

01/02/19 Alejandra Reichard Revised answers to interrogatories in response to CID from Indiana Attorney General.

0.20

01/02/19 Allison Scarlott Commenced reviewing responses to interrogatories regarding individual misconduct and personnel information based on comments from reviewer.

0.50

01/03/19 Mark D. Stuaan Communications with C.J. Schneider regarding various items relating to request from the Attorney General’s office; communications with Deputy Attorney General regarding the same; call to (left message); communication to C.J. Schneider and L. Mendoza regarding scheduling of call with Deputy Attorney General for January 4.

0.60

01/03/19 Ladene I. Mendoza Strategized with Allison Scarlott on updating Interrogatory charts assigned to Mark Busby after his responses to various pending questions.

1.00

01/03/19 Allison Scarlott Continued to work on responses to interrogatories regarding personnel and permanently ineligible members based on comments from reviewer; reviewed documents relevant to permanently ineligible members in order to respond to interrogatories.

4.80

01/04/19 Mark D. Stuaan Telephone conversation with Deputy Attorney General regarding her request for all Safe Sport complaints referred to the Center for Safe Sport by USAG; communication to C.J. Schneider and L. Mendoza regarding the same.

0.20

01/07/19 Mark D. Stuaan Telephone conversation with

; communication to C.J. Schneider regarding the same (

); communications with Cathy Allen, C.J. Schneider and L. Mendoza regarding update of "new hires" list and recent departure list; communication with L. Mendoza about providing those lists to the Attorney General’s office.

1.10

01/08/19 Mark D. Stuaan Communications with C.J. Schneider, Deputy Attorney General and Mark Busby regarding request for additional Safe Sport materials and status of compiling and producing the same in response to the civil investigative demand.

0.60





01/08/19 Ladene I. Mendoza Communication with Mark Stuaan on complaints update; corresponded to James Casteel of Miller Johnson for production of documents regarding misconduct files in Relativity and redaction issue; reviewed information related to job description for USAG Investigator in order to incorporate into Interrogatory answer.

1.50

01/09/19 Mark D. Stuaan Communication to Deputy Attorney General regarding job description for USAG’s Safe Sport investigators; worked with L. Mendoza on cover letter for production of additional misconduct materials; communication with Mark Busby regarding status of compiling list of matters referred by USAG to the Center for Safe Sport.

0.50

01/09/19 Patricia A. Ellis Received and reviewed e-mail from Ladene Mendoza regarding investigator job description documents.

0.10

01/09/19 Ladene I. Mendoza Corresponded with James Casteel and Mark Stuaan regarding production of misconduct materials; drafted production cover letter for production of misconduct materials to Indiana Attorney General's office; prepared and compiled materials before producing to Indiana Attorney General's office.

1.00

01/10/19 Mark D. Stuaan Communications with Mark Busby regarding status of compiling list of matters referred to the Center for Safe Sport by USAG and production of same to the Attorney General’s office; communications with L. Mendoza regarding the same, including information regarding most recent production of misconduct materials and next anticipated production of similar materials.

0.70

01/10/19 Ladene I. Mendoza Corresponded with Mark Stuaan regarding safe sport complaint materials; drafted description of production sets regarding misconduct materials previously produced to the Indiana Attorney General's office and upcoming production in order to send Vanessa Voigt of the Indiana Attorney General's office update of status; reviewed and sent Vanessa Voigt from the Indiana Attorney General's office an index of every USA Gymnastics case with the Center for Safe Sport as of December 20, 2018.

2.00

01/11/19 Mark D. Stuaan Considered message from Deputy Attorney General requesting copies of Safe Sport documentation for matters referred to the Center for Safe Sport by USAG; communication with L. Mendoza regarding the same.

0.20

01/11/19 Patricia A. Ellis Exchanged e-mails with Ladene Mendoza regarding document productions; updated production log and production table of documents sent to the Indiana Attorney General's office.

0.40





01/11/19 Ladene I. Mendoza Reviewed and analyzed financial documents and updated response to request for production related to financial documents in order to update language that financial documents from 2016-2017 are now available on-line; corresponded with Mark Busby and James Casteel regarding Safe Sport documents requested by the Indiana Attorney General's office via email on January 10, 2019; drafted production letter to the Indiana Attorney General's office for production of non-sexual misconduct files and related materials; corresponded with Alejandra Contreras regarding financial statements and other financial related documents produced to the Indiana Attorney General's office previously.

2.70

01/14/19 Mark D. Stuaan Communications with Deputy Attorney General and C.J. Schneider regarding status of completing productions in response to the civil investigative demand; communication with L. Mendoza regarding compilation of additional Safe Sport misconduct materials in connection with responding to the civil investigative demand.

0.30

01/14/19 Ladene I. Mendoza Corresponded and strategized with Mark Stuaan regarding Safe Sport complaints to request from James Casteel of Miller Johnson; corresponded with James Casteel and Alex Contreras of Miller Johnson regarding status update on misconduct files that were referred to Safe Sport and status of last date misconduct files were harvested for Relativity; corresponded with Amy Murphy regarding status of document production completion; and began reviewing misconduct files to determine if safe sport incident report form was included in file.

3.40

01/15/19 Mark D. Stuaan Communication with L. Mendoza regarding status of compiling additional misconduct materials for production in response to request from the Attorney General's office.

0.10

01/15/19 Ladene I. Mendoza Corresponded with Mark Stuaan and Mark Busby regarding Safe Sport files and request for incident reports submitted to Safe Sport Center; and corresponded with James Casteel regarding manual review of index for cases sent or received from Safe Sport Center in order to determine which files need collecting from USAG for uploading to Relativity.

1.10

01/17/19 Mark D. Stuaan Considered message from Deputy Attorney General reiterating request for estimated completion of response to the civil investigative demand; worked with C.J. Schneider and L. Mendoza on response to the email; telephone conversations with Mark Busby and C.J. Schneider regarding collection and uploading of additional misconduct materials from USAG; email to Deputy Attorney General regarding estimated date of completion of response to civil investigative demand.

0.80





01/17/19 Ladene I. Mendoza Corresponded with Mark Stuaan regarding Indiana Attorney General's request for a status update; Corresponded with James Casteel in order to receive an update of manual review of case files listed in index that are not in Relativity; drafted an updated status report to the Indiana Attorney General's office and sent to CJ Schneider for review and approval; and Corresponded with Mark Busby regarding interrogatories that need finalized for production to Indiana Attorney General's office.

3.30

01/18/19 Mark D. Stuaan Considered message from Mark Busby regarding information relating to one of the "Safe Sport" files.

0.10

01/21/19 Ladene I. Mendoza Reviewed and analyzed misconduct files sent by James Casteel in order to compile list of misconduct files to collect from Mark Busby to upload to Relativity; corresponded with Mark Busby regarding collection of misconduct files; corresponded with Scott Shollenbarger regarding review of financial interrogatories to send to the Indiana Attorney General's office.

1.90

01/22/19 Mark D. Stuaan Communications with Mark Busby and L. Mendoza regarding compilation of additional misconduct materials for production in response to the civil investigative demand.

0.10

01/22/19 Ladene I. Mendoza Reviewed misconduct files received from USA Gymnastics that were not previously uploaded to Relativity in order to determine if any files were missing and which files need to be scanned.

1.00

01/23/19 Ladene I. Mendoza Continued reviewing hard copy misconduct files received from USA Gymnastics that were not previously uploaded to Relativity in order to determine if any files missing and which files need to be scanned; corresponded with Scott Shollenbarger to review and explain financial interrogatories previously drafted after John Hewett's review and comments.

3.40

01/24/19 Mark D. Stuaan Communication with L. Mendoza regarding process for producing additional Safe Sport materials to the Attorney General's office following her phone conversation with C.J. Schneider; considered communications between L. Mendoza and Mark Busby regarding the compilation of additional Safe Sport materials for production to the Attorney General's office.

0.20

01/24/19 Ladene I. Mendoza Continued review of misconduct files to determine which files still need to be collected and which files need to be scanned; corresponded with CJ Schneider and Mark Stuaan regarding the misconduct files that were included in the hard copy box in order to determine where to send misconduct files that are already on Relativity; corresponded with Mark Busby to communicate plan of sending files to Miller Johnson to review and to provide list of files that were not included in hard copy box; corresponded with Scott Shollenbarger to finalize financial interrogatories.

7.00





01/25/19 Mark D. Stuaan Worked with L. Mendoza in finalizing cover letter for next production to the Attorney General's office; communication with L. Mendoza regarding status of compiling and producing Safe Sport materials and files; communication with C.J. Schneider regarding question from the Deputy Attorney General regarding the off-site storage of records by USAG at Iron Mountain; considered information from C.J. Schneider and co-counsel regarding the same.

0.70

01/25/19 Ladene I. Mendoza Corresponded with CJ Schneider regarding review of financial interrogatories; corresponded with CJ Schneider and James Casteel regarding approach of producing misconduct files related to review of privilege information by

; drafted production letter to Indiana Attorney General's office with misconduct file materials and various answers to interrogatories; corresponded with Mark Busby regarding files that were missing from 2018 hard copy box; compiled and prepared misconduct files for production and produced documents and various answers to interrogatories to the Indiana Attorney General's office; corresponded with Patricia Ellis to include production on production log and table.

4.50

01/28/19 Mark D. Stuaan Communications with C.J. Schneider and Alejandra Contreras regarding information relating to the off-site storage of records by USAG at Iron Mountain; reviewed and considered information provided by co-counsel and USAG regarding the off-site storage of records by USAG; communication to Deputy Attorney General in response to question about the off-site storage of records by USAG at Iron Mountain in Pennsylvania; communication with C.J. Schneider regarding six letters received by USAG from the Indiana Department of Children Services.

2.50

01/28/19 Patricia A. Ellis Updated production table and Attorney General production log of January 11 and January 25, 2019 document productions.

0.30

01/28/19 Ladene I. Mendoza Began reviewed and analyzed second hard copy box of misconduct materials received and sent an individual member's misconduct file to be scanned by resource center on urgent request for production today by Miller Johnson.

1.10

01/30/19 Ladene I. Mendoza Continued reviewing newly received misconduct files in hard copy box number two in order to determine misconduct files that need uploading into Relativity in order to prepare for scanning.

2.20

01/31/19 Ladene I. Mendoza Began drafting list of misconduct files received from USAG in order to track of misconduct files received and returned or mailed to Miller Johnson; corresponded and provided James Casteel with 27 additional misconduct files that were not previously found on Relativity for production to Indiana Attorney General's office.

1.80




Fees for Services Total $ 21,020.93

Other Charges:

Messenger Courier Service 10.00

Copying Charges 20.25

Pacer Court Filing System Charges 12/1/2018-12/31/2018

1.80

$ 32.05




(317) 236-1313

Invoice 2197583













EXHIBIT C

Barnes & Thornburg LLP March 21, 2019 Invoice




(317) 236-1313

Invoice 2208257


March 21, 2019Mark D. Stuaan00075094-000001













(317) 236-1313





00075094-000001

INVESTIGATIONS

For legal services rendered in connection with the above matter for the period ending February 28, 2019 as described on the attached detail.








02/01/19 Mark D. Stuaan Communication with L. Mendoza regarding status of compiling additional documents to be provided in response to the civil investigative demand; telephone conversation with Mark Busby regarding the same.

0.30

02/02/19 Ladene I. Mendoza Prepared, collected and compiled misconduct files requested from the department of child services in Utah before sending to Miller Johnson for uploading to Relativity database.

3.10

02/04/19 Mark D. Stuaan Communication with L. Mendoza regarding status of providing additional documents and answers to interrogatories in response to the civil investigative demand; reviewed the USAG web-site for current versions of various policies and procedures, in connection with draft answers to interrogatories and responses to requests for production.

0.70

02/04/19 Patricia A. Ellis Updated production spreadsheets of document production to Indiana Attorney General's office and sent e-mail to Ladene Mendoza regarding same.

0.40

02/05/19 Mark D. Stuaan Communication with C.J. Schneider regarding most recent update to the USAG report on progress of implementing recommendations from ; communications with L. Mendoza regarding status of draft answers to interrogatories awaiting review and approval by Mark Busby; worked on compiling revised draft answers to interrogatories awaiting Mark Busby review and approval, and forwarded same to Mark Busby for review; reviewed the USAG Bylaws relating to a comment by Mark Busby concerning Article 9.2 and the process for certain disciplinary measures without a panel hearing (relating to a draft answer to an interrogatory in the CID); communications with Mark Busby regarding the same.

4.30

02/05/19 Ladene I. Mendoza Corresponded and strategized with Mark Stuaan on upcoming deadlines communicated with the Indiana Attorney General's office and began assigning tasks for completion this week.

0.50

02/06/19 Mark D. Stuaan Communications with Mark Busby regarding his review and approval of language in draft answers to various interrogatories in the civil investigative demand.

0.20

02/06/19 Ladene I. Mendoza Corresponded with Mark Stuaan on timeline discussed with Indiana Attorney General's office and corresponded with Allison Scarlott on collecting and compiling all answers to the Indiana Attorney General's interrogatories in order to have complete final answers submitted to the Indiana Attorney General's office.

0.70

02/07/19 Mark D. Stuaan Communications with Mark Busby and L. Mendoza about compiling, and preparing for production to the AG, additional misconduct materials and documents.

0.30





02/07/19 Ladene I. Mendoza Reviewed Mark Busby's comments about his assigned Interrogatories from the Indiana Attorney General's office and drafted updates and incorporated additions to Interrogatory answers; corresponded with Mark Busby regarding interrogatory updates; met with Alejandra Reichard and Allison Scarlott regarding strategy for updates to request for production of documents; drafted production letter to the Indiana Attorney General's office; and drafted final Interrogatories for Mark Busby to review in order to submit to Indiana Attorney General's office.

9.40

02/07/19 Allison Scarlott Compiled all finalized responses to Interrogatories and certifications of truth to prepare to send to the Attorney General; reviewed all 110 responses to Interrogatories to finalize language.

4.20

02/08/19 Mark D. Stuaan Worked with L. Mendoza and client in producing answers to interrogatories from the civil investigative demand; worked with L. Mendoza on the cover letter for the production.; worked on revising draft responses to various requests for production of documents.

3.20

02/08/19 Patricia A. Ellis Updated production log of February 7, 2019 Interrogatory responses to the Indiana Attorney General and conferred with Ladene Mendoza regarding same.

0.30

02/08/19 Ladene I. Mendoza Corresponded with Mark Busby in order to follow up on outstanding discovery requests; drafted additional updates to outstanding interrogatory answers after Mark Stuaan's review and comments; corresponded with CJ Schneider on reviewing interrogatory related to compliance with the Young Victims Act; drafted production letter for misconduct material to the Indiana Attorney General's office; updated master timeline with production made to the Indiana Attorney General's office and corresponded with Patricia Ellis to include latest production in the production table and log.

4.30

02/08/19 Allison Scarlott Reviewed compiled Answers to Interrogatories from Mark Busby in order to continue to finalize the Answers.

1.40

02/10/19 Patricia A. Ellis Updated production log and table of document production sent to the Indiana Attorney General's office.

0.40

02/11/19 Mark D. Stuaan Continued review and revision of draft responses to RFP Nos. 46-58; communication with L. Mendoza regarding the same; considered message from C.J. Schneider regarding suggested revisions to draft answers to Interrogatories Nos. 30, 49, 50 and 72.

1.10

02/11/19 Ladene I. Mendoza Corresponded with CJ Schneider regarding updates to Interrogatory responses including interrogatory related to compliance with the Young Victims act and incorporated CJ Schneider's changes to the interrogatory answers.

1.10





02/12/19 Mark D. Stuaan Communication with C.J. Schneider regarding question from Deputy Attorney General requesting date of completion of response to the civil investigative demand; participated in conference call with C.J. Schneider, Alejandra Contreras and L. Mendoza regarding the same; communication to C.J. Schneider with draft response to the Deputy Attorney General's question.

0.80

02/12/19 Ladene I. Mendoza Strategized with CJ Schneider and Alex Contreras of Miller Johnson regarding document production of Request for Production of Documents; drafted production letter of final Interrogatories and compiled documents for production to the Indiana Attorney General's office; corresponded with James Casteel of Miller Johnson to determine whether all misconduct and safe sport materials recently loaded in Relativity have all been produced to the Indiana Attorney General's office; corresponded with Mark Busby and Emily Zorn regarding additional misconduct materials that may need collecting.

3.40

02/12/19 Allison Scarlott Finalized Response to Interrogatory No. 1, 30, 49, 50, and 72 and reviewed document for consistency and accuracy to send to Indiana Attorney General.

1.50

02/13/19 Mark D. Stuaan Communications with L. Mendoza regarding production of documents to the Attorney General; communication with colleagues regarding revision of draft responses to various RFPs; worked on revising draft responses to RFPs 23-45.

1.20

02/13/19 Ladene I. Mendoza Finalizing answers for the Indiana Attorney General's Interrogatories and produced to the Indiana Attorney General a document compiling the answers provided today and previously provided Answers to Interrogatories; Corresponded with Mark Stuaan regarding production to the Indiana Attorney General's office; and drafted summary and request of issue tags still needed and search terms that needed to be created and reviewed and sent to James Casteel and Alejandra Contreras of Miller Johnson in order to finalize production of documents to Indiana Attorney General's office.

6.10

02/13/19 Allison Scarlott Evaluated and drafted responses to Requests for Production Nos. 23-45 by comparing the request with the response for any corresponding interrogatory; reviewed each Response to determine if information was updated and remained relevant.

2.80

02/14/19 Mark D. Stuaan Continued work on revising draft responses to various RFPs; worked on revising draft answers to ROGs 23-45; communication with L. Mendoza regarding status of compiling documents, uploading documents into Relativity and pulling documents for production to the Indiana Attorney General; communication with Deputy Attorney General, L. Mendoza and C.J. Schneider regarding conference call to discuss estimated date of completion of responding to the civil investigative demand.

2.40





02/14/19 Ladene I. Mendoza Teleconference with James Casteel and Alejandra Contreras of Miller Johnson on follow up questions of requests sent in order to finalize production of documents in the relativity database to the Indiana Attorney General's office; prepared and compiled misconduct files to send to Miller Johnson and drafted list of misconduct files sent in order to keep track of files and determine which 2018 misconduct files were still outstanding and requested from the Indiana Attorney General's office.

3.30

02/14/19 Alejandra Reichard Reviewed answers to requests for productions, revised for compatibility with interrogatory responses that all information included was up to date.

1.80

02/15/19 Mark D. Stuaan Worked on revising draft responses to RFPs 23-45; communications with co-counsel regarding various matters; prepared for conference call with Deputy Attorney Generals; conferred with C.J. Schneider and L. Mendoza prior to and following conference call with Deputy Attorney Generals; participated in conference call with Deputy Attorney Generals, C.J. Schneider and L. Mendoza regarding development of estimated date of completion of response to the civil investigative demand.

2.30

02/15/19 Ladene I. Mendoza Prepared for and attended call with CJ Schneider, Mark Stuaan and Indiana Attorney General's office regarding status of requests from the Civil Investigative Demand; corresponded with James Casteel and Alejandra Contreras regarding update of searches and requests for issue tag in order to receive update of deadline to provide to the Indiana Attorney General's office.

1.20

02/16/19 Allison Scarlott Reviewed updates to Responses for the Requests for Production Nos. 23-46 and investigated whether responsive documents exist and/or have been previously provided to the office of the Attorney General for the 'Together We Can' and 'Clubs Care' initiatives.

0.60

02/18/19 Ladene I. Mendoza Corresponded with James Casteel of Miller Johnson regarding production of issue tag 10 and 11 and procedure for documents that hit on privilege terms; began reviewing Allison Scarlott and Alejandra Reichard's draft updates in responses to Request for Production from the Indiana Attorney General's office; began drafting updates to Responses to Request Nos. 59-81 related to financial requests.

6.60

02/19/19 Mark D. Stuaan Communications with CJ Schneider regarding USAG's new President; communication to Deputy Attorney General concerning the same; further work on draft responses to RFPs 82 through 91.

1.10





02/19/19 Ladene I. Mendoza Reviewed materials produced to the Indiana Attorney General's office regarding misconduct files, issue tags, and searches and reviewed e-mails to summarize efforts recently done in order to determine outstanding tasks to finalize production; corresponded with James Casteel and Alex Contreras with updates regarding timelines to finalize production to Indiana Attorney General and to determine if the end of March was feasible for completion date to provide to the Indiana Attorney General's office; continued review of responses to request for production Nos. 23-45 and compared responses to the production table that will be provided with the responses in order to make sure the two documents are consistent.

6.00

02/20/19 Mark D. Stuaan Communications with CJ Schneider and L. Mendoza about compiling responses to CID and compilation of responsive documents; worked with L. Mendoza on cover letter for next production to AG's office.

0.90

02/20/19 Ladene I. Mendoza Corresponded with CJ Schneider and Mark Stuaan regarding request for 2018 Safe Sport notices or incident reports from the Indiana Attorney General's office; continued to update draft responses to the requests for production; drafted production letter for misconduct files to produce to the Indiana Attorney General's office; updated master timeline with production and corresponded with Patricia Ellis to add the production made to the Indiana Attorney General's office to the production log and table.

2.80

02/21/19 Mark D. Stuaan Communications with co-counsel and colleagues regarding review of materials relating to allegations of misconduct; worked with co-counsel, colleagues and client on collection of materials and the review of those materials and documents.

1.40

02/21/19 Ladene I. Mendoza Collected hard copy misconduct files from USA Gymnastics office and began reviewing documents relating to allegations of misconduct in order to identify misconduct files on list provided by Miller Johnson that needed uploading to Relativity.

9.60

02/22/19 Mark D. Stuaan Communications with colleagues and co-counsel regarding review of documents concerning allegations of misconduct in preparation for further production in response to AG's civil investigative demand.

1.60

02/22/19 Donald E. Thomas Worked with colleagues and co-counsel on reviewing documents relating to allegations of misconduct and compiling results of document review.

6.20

02/22/19 Ladene I. Mendoza Worked with colleagues and co-counsel on reviewing documents relating to allegations of misconduct and compiling results of document review.

12.70

02/22/19 Amit Patel Worked with colleagues and co-counsel on reviewing documents relating to allegations of misconduct and compiling results of document review

10.30





02/23/19 Donald E. Thomas Reviewed and analyzed list of misconduct files sent or received from the center in 2018 in order to determine additional misconduct files still needed to collect and/or scan for Indiana Attorney General's request for all Safe Sport notices in 2018; sent list compiling information to L. Mendoza for review.

1.30

02/23/19 Ladene I. Mendoza Continued review of documents relating to allegations of misconduct and compiling results of document review to be uploaded to Relativity; sent summary of findings to Miller Johnson of what was complete and sent scanned misconduct files to Miller Johnson for uploading to Relativity.

14.00

02/25/19 Mark D. Stuaan Communications with Rebecca Strauss, L. Mendoza and others relating to review, and anticipated production, of files and documents concerning allegations of misconduct; communications with Emily Zorn regarding same; email to colleagues and co-counsel following meeting with Emily Zorn regarding compilation of files and materials relating to allegations of misconduct.

2.40

02/25/19 Donald E. Thomas Worked with colleagues and co-counsel on reviewing documents relating to allegations of misconduct and compiling results of document review.

5.60

02/25/19 Patricia A. Ellis Updated production spreadsheets of February 20 and 21, 2019 document productions to the Indiana Attorney General.

0.40

02/25/19 Ladene I. Mendoza Continued work with colleagues and co-counsel on reviewing documents relating to allegations of misconduct and compiling results of document review; began reviewing 2018 Safe Sport materials on list that still needed to be sent to the Indiana Attorney General's office; began reviewing drop box files to determine if any of those materials aligned with materials to be collected in response to the Indiana Attorney General's office; corresponded with Alex Contreras and James Casteel of Miller Johnson regarding information Mark Busby provided with respect to misconduct files.

7.20

02/25/19 Amit Patel Worked with colleagues and co-counsel on reviewing documents relating to allegations of misconduct and compiling results of document review

4.90

02/26/19 Mark D. Stuaan Worked with co-counsel, colleagues and client in compiling misconduct materials and documents for further production to Indiana Attorney general's civil investigative demand.

1.30

02/26/19 Ladene I. Mendoza Reviewed and collected 2018 Safe Sport materials received from Emily Zorn of USA Gymnastics in order to send for uploading to Relativity; began updating spreadsheet of 2018 Safe Sport materials still outstanding in order to request Safe Sport material from Mark Busby to send to the Indiana Attorney General's office March 5 deadline imposed.

8.20





02/27/19 Mark D. Stuaan Communications with colleagues and client regarding compilation, and production of materials and documents to the Indiana AG's office, relating to misconduct allegations; communication with L. Mendoza regarding the same.

0.20

02/27/19 Ladene I. Mendoza Corresponded with James Casteel of Miller Johnson and Mark Busby with respect to the misconduct files, e-mails sent to or received by US Center for Safe Sport in 2018 or incident reports sent to or received from the Center in 2018 in order to collect all outstanding Center material requested for the Indiana Attorney General's office by March 5; reviewed and analyzed recently loaded misconduct materials on Relativity for privilege and sent summary of findings to James Casteel and Alejandra Contreras of Miller Johnson.

6.70

02/28/19 Mark D. Stuaan Communications with L. Mendoza and Mark Busby regarding compilation of additional materials relating to allegations of misconduct reported to the Center by USAG or notice of reports to the Center relayed to USAG; communication with Deputy Attorney General regarding status of producing additional documents relating to allegations of misconduct reported to, or reported from, the Center in 2018.

0.80

02/28/19 Ladene I. Mendoza Corresponding with Miller Johnson regarding updates of production to the Indiana Attorney General's office; corresponded with Mark Stuaan regarding updates on production to the Indiana Attorney General's office; reviewed and collected Safe Sport materials from 2018 from Mark Busby and sent to Miller Johnson for uploading to Relativity; began updating spreadsheet with misconduct files and Safe Sport materials received to track files obtained and to be produced to the Indiana Attorney General's office.

8.40


Other Charges:

Courier Service Fedex - Inv#644794190 - to Christopher Schneider James C, Miller Johnson, GRAND RAPIDS, MI, US from Ladene Mendoza

35.99

Courier Service Fedex - Inv#646901993 - to James W Casteel, Miller Johnson, GRAND RAPIDS, MI, US from Ladene Mendoza

29.90

$ 65.89




(317) 236-1313

Invoice 2208257













EXHIBIT D

Barnes & Thornburg LLP April 19, 2019 Invoice




(317) 236-1313

Invoice 2217622


April 19, 2019Mark D. Stuaan00075094-000001








Other Charges $ 1,510.14





(317) 236-1313





00075094-000001

INVESTIGATIONS

For legal services rendered in connection with the above matter for the period ending March 31, 2019 as described on the attached detail.








03/01/19 Mark D. Stuaan Communications with colleagues and co-counsel regarding production of documents relating to various allegations under the Safe Sport jurisdiction; worked with L. Mendoza on production of documents to the Indiana Attorney General.

0.40

03/01/19 Ladene I. Mendoza Drafted two production letters to provide to the Indiana Attorney General related to issue tagged documents reviewed and misconduct materials sent or received by the U.S. Center for Safe Sport in 2018; collected and produced documents to the Indiana Attorney General's office; updated master timeline with production; and corresponded with Patricia Ellis to update production log and table with production.

3.20

03/04/19 Mark D. Stuaan Communications with Mark Busby regarding upcoming meeting on March 5 with representatives of the Attorney General's office; communication with C.J. Schneider regarding phone conversation with Mark Busby; communications with L. Mendoza regarding question relating to the PIM lists and the possible existence of "old" PIM lists.

0.80

03/04/19 Patricia A. Ellis Updated production log and production table of document productions from March 1, 2019 sent to Indiana Attorney General.

0.40

03/04/19 Ladene I. Mendoza Reviewed and analyzed updated document review protocol Alejandra Contreras was planning on providing to Epiq and provided edits and clarifications of review protocol as it relates to the Indiana Attorney General requests; Corresponded with James Casteel regarding status of supplemental production to provide to the Indiana Attorney General related to the misconduct materials sent to or received by the U.S. Center for Safe Sport; drafted production letter and produced documents related to Safe Sport 2018 materials; drafted update to master timeline to incorporate production; and corresponded to Patricia Ellis to incorporate today's production to production log and table.

1.80

03/05/19 Mark D. Stuaan Reviewed list of topics to be discussed during meeting with representatives of the Attorney General's office in preparation for the meeting; conferred with Melissa Root, Catherine Steege and C.J. Schneider prior to meeting with representatives of the Attorney General's office; participated in meeting with Melissa Root, Catherine Steege, C.J. Schneider, Shelba Waldron and Mark Busby in preparation for meeting with representatives of the Attorney General's office; attended meeting with representatives of the Attorney General's office; conferred with Melissa Root, Catherine Steege, C.J. Schneider, Shelba Waldron and Mark Busby following the meeting.

4.90

03/05/19 Patricia A. Ellis Updated production log and production table of document production from March 4, 2019 sent to Indiana Attorney General.

0.30





03/06/19 Mark D. Stuaan Reviewed USAG website regarding update to the Progress Report concerning the ; drafted language for revised answer to one of the RFPs related to the

; communication with L. Mendoza regarding the same; communications to Mark Busby and C.J. Schneider in follow up to the March 5 meeting with Attorney General representatives; communications with Mark Busby regarding an email sent by USAG to various members relating to Safe Sport updated requirements (in follow up to the March 5 meeting); communication with L. Mendoza regarding revised language to RFP concerning the .

0.90

03/06/19 Ladene I. Mendoza Corresponded with Alex Contreras of Miller Johnson regarding Epiq's review of additional issue tags and request for former PIM list requested by the Indiana Attorney General; reviewed and analyzed previous production in order to determine whether additional job descriptions other than that of Safe Sport personnel were previously sent to the Indiana Attorney General's office; reviewed and analyzed documents to determine if we had collected other requested position descriptions for USA Gymnastics personnel; reviewed publicly available information to determine if additional position descriptions for USA Gymnastics personnel was available to provide to the Indiana Attorney General's office; and provided former PIM list request and current responses to the request for production to Mark Stuaan with explanation of comments related to to review.

4.20

03/07/19 Mark D. Stuaan Communications with L. Mendoza and C.J. Schneider regarding job or position descriptions for various USAG personnel; communication with L. Mendoza regarding clarification of question from Alejandra Contreras about lists of permanently ineligible members and lists of misconduct files/materials in Relativity.

0.30

03/07/19 Ladene I. Mendoza Corresponded with Alex Contreras of Miller Johnson after Mark's Stuaan's comments and suggestions with respect to the Indiana Attorney General's request for former PIM lists and provided previous USAG response in connection with request related to former PIM lists provided to a congressional committee's request in order to ensure responses are correct and still consistent with prior response; drafted updated discovery response in the request for production of documents to include job description of president and CEO and included link from website.

1.10

03/08/19 Mark D. Stuaan Communications with Mark Busby regarding "blast" email to Club owners and/or administrators relating to Safe Sport.

0.20





03/12/19 Ladene I. Mendoza Corresponded with James Casteel regarding production of documents recently provided in order to communicate concern of privileged documents found after spot check of production and the need for those documents to be excluded from production set and re-reviewed for privilege and provided examples of privileged documents; corresponded with James Casteel and provided update regarding issue with privileged document in order to communicate that it was limited to production set 40 and did not include production set 41 since those documents were a set of supplemental documents that were specifically reviewed for privilege by Epiq.

1.40

03/13/19 Mark D. Stuaan Communications with Mark Busby and Erica Koven regarding November 2018 communication to club owners and/or club administrators regarding Safe Sport updates; considered additional communications from USAG to club owners and/or club administrators and/or professional members regarding Safe Sport in early 2019; communication with L. Mendoza regarding draft of language for production of the November 2018 communication to club owners and/or administrators.

0.80

03/13/19 Ladene I. Mendoza Drafted production letter to Indiana Attorney General's office regarding contracts with independent contractors and job descriptions of senior positions in response to the Civil Investigative Demand; reviewed new hires spreadsheet to determine whether additional requests for job descriptions exist based on previous positions no longer existing; corresponded with James Casteel to provide documents to load into Relativity and bates-label for production to the Indiana Attorney General's office; reviewed and analyzed misconduct files in order to correspond with Mark Busby and provide electronic misconduct file of a previous USA Gymnastics' member in response to the Center for Safe Sport and information regarding documents previously withheld from production due to privilege in the misconduct file.

2.10

03/14/19 Mark D. Stuaan Worked with L. Mendoza regarding cover letter for next production to the Attorney General's office; considered information from L. Mendoza regarding productions by Miller Johnson to Ropes & Gray and Congressional entities; communication to C.J. Schneider regarding the same.; communications with client and C.J. Schneider regarding request from the Center for Safe Sport for documents and materials relating to ; participated in conference call with USAG co-counsel regarding status of various matters.

2.10





03/14/19 Ladene I. Mendoza Corresponded with Alex Contreras and James Casteel requesting update on production and whether we were still on track to produce with timeline provided to the Indiana Attorney General's office; corresponded with Mark Stuaan and CJ Schneider in order to provide update regarding gaps in bates-numbers in upcoming production due to privilege documents removed from production set and strategy in communicating issue with the Indiana Attorney General's office; drafted cover letter for production of email that the Indiana Attorney General's office requested on March 5th related to Safe Sport communications; corresponded with Patricia Ellis to request last productions recorded in production log or table by Miller Johnson to Congressional Committees and Ropes & Gray in order to determine if additional productions need to be made to the Indiana Attorney General's office.

2.20

03/15/19 Mark D. Stuaan Communication with L. Mendoza regarding status of next production of documents in response to the CID; continued work on revising draft responses to RFPs 82 through 91; forward same to L. Mendoza; communication to C.J. Schneider in connection with determining whether additional productions to Congressional entities and/or Ropes & Gray are subject to being provided to the Indiana Attorney General.

0.90

03/15/19 Ladene I. Mendoza Corresponded with Alex Contreras and James Casteel regarding decision to manually extract the inadvertently included pages that are considered privileged from the production set and provide the Indiana Attorney General's office with a list of corresponding missing bates numbers; drafted summary of last two productions by Miller Johnson to Ropes & Gray and to congressional committees and whether the production was produced to the Indiana Attorney General's office after Patricia Ellis's initial email; updated production log with productions that were not previously added from Barnes & Thornburg and Miller Johnson and provided summary of production to Mark Stuaan for review.

3.10

03/18/19 Patricia A. Ellis Received and reviewed e-mail from Ladene Mendoza regarding document production to the Indiana Attorney General.

0.10

03/22/19 Mark D. Stuaan Communication with L. Mendoza regarding upcoming production to the Indiana Attorney General; worked with L. Mendoza regarding cover letter for production of documents.

0.20

03/22/19 Ladene I. Mendoza Drafted production letter for production of issue tagged documents and updated master timeline to incorporate production; corresponded with Patricia Ellis to provide production and to request she add production to the production log and table.

2.00

03/25/19 Mark D. Stuaan Communications with C.J. Schneider regarding various matters, including production of settlement agreements relating to to the Center for Safe Sport.

0.20





03/25/19 Patricia A. Ellis Updated document productions to the Indiana Attorney General sent on March 14 and March 22 to production spreadsheets.

0.40

03/29/19 Mark D. Stuaan Communication with L. Mendoza regarding upcoming production to the Attorney General's office; worked with L. Mendoza on finalizing the cover letter for the production and in making the production.

0.20

03/29/19 Ladene I. Mendoza Drafted production letter of multiple issue tagged documents; collected and produced documents to the Indiana Attorney General's office; updated master timeline with production; and corresponded with Patricia Ellis to update production log and table with production.

4.30

03/30/19 Patricia A. Ellis Exchanged e-mails with Ladene Mendoza regarding March 29th document production to Indiana Attorney General and updated production spreadsheets.

0.40


Other Charges:

Courier Service Express Delivery Today LLC 28 boxes shipped to James Caseteel, Miller Johnson Law Firm in Grand Rapids MI on 2/26/19 Inv Number: 11834 03/03/2019

1,475.00

Business Meals Finner, LLC dba Jimmy John's Lunch - USAG meeting Inv Number: 03052019-52 03/05/2019

35.14

$ 1,510.14




(317) 236-1313

Invoice 2217622













EXHIBIT E

Barnes & Thornburg LLP May 17, 2019 Invoice




(317) 236-1313

Invoice 2224882


May 17, 2019Mark D. Stuaan00075094-000001













(317) 236-1313



May 17, 2019Mark D. Stuaan00075094-000001


00075094-000001

INVESTIGATIONS

For legal services rendered in connection with the above matter for the period ending April 30, 2019 as described on the attached detail.








04/04/19 Ladene I. Mendoza Drafted summary of status update of production of documents to provide to Mark Stuaan; corresponded with Alex Contreras at Miller Johnson to obtain update on status of searches that were run for Epiq to review; and corresponded with James Casteel of Miller Johnson regarding update of production of documents.

1.20

04/05/19 Ladene I. Mendoza Reviewed and analyzed documents requested by Indiana Attorney General in order to determine status of native format document and whether it was possible to produce in non-pdf format; and corresponded with the Indiana Attorney General's office regarding request for documents after confirming on Relativity database.

0.60

04/12/19 Ladene I. Mendoza Drafted production letter to the Indiana Attorney General's office and communicated with CJ Schneider regarding production today to the Indiana Attorney General's office.

0.60

04/13/19 Ladene I. Mendoza Reviewed, revised and updated responses to the Indiana Attorney General's office's Request for Production of Documents in order to finalize before client review and approval.

9.00

04/13/19 Ladene I. Mendoza Revised and drafted production letter to the Indiana Attorney General's office and collected documents for production to the Indiana Attorney General's office; updated master timeline with production.

1.00

04/15/19 Ladene I. Mendoza Continued revisions and updates to responses to the Indiana Attorney General's office's Request for Production of Documents after reviewing updated policies and information on USAG website and sent to CJ Schneider for review and approval.

2.20

04/16/19 Ladene I. Mendoza Drafted draft email to send to Indiana Attorney General's office regarding status of documents and responses to requests for production of documents from USAG after reviewing previous updates and emails and sent to Mark Stuaan for review.

0.80

04/17/19 Mark D. Stuaan Communications with C.J. Schneider regarding letter to the Indiana Attorney General about recently discovered documents

; reviewed the letter and forwarded same to the AG's office; communication to C.J. Schneider regarding forward of letter to the AG's office; communication to C.J. Schneider regarding draft of email to the AG's office providing update on status of production of documents in response to the CID.

0.40

04/17/19 Patricia A. Ellis Updated production log and table and reviewed both documents for missing productions; sent missing production bate-ranges to Ladene Mendoza via e-mail.

0.80

04/18/19 Mark D. Stuaan Participated in conference call with co-counsel regarding various matters, including the recently retrieved documents from the Ranch; communication with L. Mendoza regarding the same.

0.60





04/19/19 Mark D. Stuaan Communication with C.J. Schneider and L. Mendoza regarding update on status to be provided to the Indiana Attorney General; communications with Rebecca Strauss regarding review and uploading of documents recently retrieved from the Ranch; communication to the Indiana Attorney General providing update on status of producing documents in response to the CID.

0.30

04/19/19 Ladene I. Mendoza Drafted production letter to the Indiana Attorney General's office and sent to Mark Stuaan for review and comment.

0.40

04/20/19 Ladene I. Mendoza Updated and revised production letter to the Indiana Attorney General's office; collected and produced production of documents; updated master timeline to include production.

1.10


Other Charges:

Conference Call Charges Inv# 3172361313-031219 Moderator Ladene Mendoza Time of Call 12:54PM

17.56

$ 17.56




(317) 236-1313

Invoice 2224882


May 17, 2019Mark D. Stuaan00075094-000001











EXHIBIT F

Barnes & Thornburg LLP June 17, 2019 Invoice




(317) 236-1313

Invoice 2234635


June 17, 2019Mark D. Stuaan00075094-000001













(317) 236-1313





00075094-000001

INVESTIGATIONS

For legal services rendered in connection with the above matter for the period ending May 31, 2019 as described on the attached detail.








05/01/19 Mark D. Stuaan Communication to Rebecca Strauss requesting update on status of uploading and review of documents

; communication with L. Mendoza regarding follow up with C.J. Schneider on his review of the draft responses in connection with the RFPs in the CID.

0.10

05/02/19 Mark D. Stuaan Communication from Rebecca Strauss providing update on the uploading and review of documents retrieved from the

in April; telephone conversation with C.J. Schneider regarding an update on status of various items.

0.20

05/03/19 Mark D. Stuaan Considered message from Attorney General making request for 2019 Safe Sport documents and information relating to Edward Nyman; communications with L. Mendoza and C.J. Schneider regarding the same.

0.70

05/03/19 Ladene I. Mendoza Began reviewing and revising responses to the Indiana Attorney General's request for production after reviewing comments from CJ Schneider.

1.70

05/05/19 Ladene I. Mendoza Corresponded with Miller Johnson and provided list of board members and committees previously produced to the Indiana Attorney General's office after reviewing emails and previous spreadsheets with draft interrogatory responses; and corresponded with Miller Johnson regarding personnel at USA Gymnastics that helped compile list of board members and committee members and explanation of how lists were compiled using various resources.

3.50

05/07/19 Mark D. Stuaan Communication with L. Mendoza regarding update on compilation and production of documents relating to

and Safe Sport documentation in 2019; considered response to request for update from Alex Contreras.

0.10

05/09/19 Mark D. Stuaan Communication with L. Mendoza regarding production of documents to the Attorney General relating to ; participated in conference call regarding update on various investigations; review of documents and production of documents in connection with various investigations.

0.80

05/09/19 Ladene I. Mendoza Drafted production letter to Indiana Attorney General's office regarding informal request for misconduct files of individuals; corresponded with Mark Stuaan regarding individual's misconduct file previously produced to the Indiana Attorney General's office and new bates-labels assigned; corresponded with Amy Murphy of Miller Johnson to provide final word document version of USA Gymnastics' verified answers in response to the Indiana Attorney General's CID; corresponded with James Casteel of Miller Johnson to request an updated spreadsheet of misconduct files located on Relativity in order to determine 2019 misconduct files and documents not yet provided to the Indiana Attorney General's office; drafted email correspondence to the Indiana Attorney General's office regarding further clarification of request for updated filings for the entirety of 2019.

4.20





05/10/19 Mark D. Stuaan Communication with L. Mendoza regarding cover letter for next production to the Attorney General's office and email to the Deputy Attorney General requesting clarification on other portion of their request.

0.20

05/13/19 Mark D. Stuaan Communication with co-counsel and colleagues regarding retention of

.

0.10

05/13/19 Ladene I. Mendoza Drafted update on and provided to Mark Stuaan for review in response to requests from Rebecca Strauss of Miller Johnson.

0.40

05/15/19 Mark D. Stuaan Considered communication from C.J. Schneider regarding return of complaint files to USAG; conferred with L. Mendoza regarding the same; considered communications with Mark Busby regarding return of materials from B&T and materials from Miller Johnson.

0.10

05/15/19 Ladene I. Mendoza Corresponded with Alex Contreras of Miller Johnson regarding the Indiana Attorney General's informal request in order to strategize collection efforts.

1.80

05/16/19 Mark D. Stuaan Communication with Rebecca Strauss and L. Mendoza regarding possible production of documents retrieved in April from .

0.10

05/21/19 Mark D. Stuaan Preliminary review of grand jury subpoena from the District of Columbia; communication with L. Mendoza regarding the same; communication to Rebecca Strauss regarding the grand jury subpoena.

0.30

05/22/19 Mark D. Stuaan Considered communication from Rebecca Strauss regarding USAG's receipt of grand jury subpoena from the District of Columbia ; further review and consideration of the subpoena; communications with L. Mendoza regarding the same.

0.40

05/23/19 Mark D. Stuaan Participated in conference call with Rebecca Strauss, her colleagues, and L. Mendoza regarding grand jury subpoena from the District of Columbia as it might relate to documents previously produced in response to the Indiana Attorney General's civil investigative demand; participated in conference call with co-counsel relating to the status of various items, including status of producing documents in response to the grand jury subpoena from the District of Columbia.

1.90

05/23/19 Ladene I. Mendoza Prepared for and attended call related to previous productions made to the Indiana Attorney General's office and provided document materials to Miller Johnson.

1.70





05/29/19 Mark D. Stuaan Telephone conversation with C.J. Schneider regarding updates on various matters; considered communication from Mark Busby requesting search of the database concerning a specific individual being considered for contract employment by USAG; communication with L. Mendoza regarding the same; considered communications between L. Mendoza and Miller Johnson regarding search of database; considered email from Alex Contreras to Mark Busby regarding results of database search.

0.50

05/30/19 Ladene I. Mendoza Worked on responding to Indiana Attorney General's request for safe sport materials and DOJ request.

2.60

05/31/19 Mark D. Stuaan Communication with L. Mendoza and others regarding update on compilation of Safe Sport documentation for 2019 in response to AG's civil investigative demand.

0.10


Other Charges:


$ 10.00




(317) 236-1313

Invoice 2234635













EXHIBIT G

Barnes & Thornburg LLP July 16, 2019 Invoice




(317) 236-1313

Invoice 2242099


July 16, 2019Mark D. Stuaan00075094-000001













(317) 236-1313





00075094-000001

INVESTIGATIONS

For legal services rendered in connection with the above matter for the period ending June 30, 2019 as described on the attached detail.








06/03/19 Mark D. Stuaan Considered message from Deputy Attorney General requesting update on production of Safe Sport documents for 2019; communicatoin with L. Mendoza regarding the same.

0.20

06/04/19 Mark D. Stuaan Communications with L. Mendoza regarding production of additional Safe Sport documents to the Attorney General; responded to request for update on production of Safe Sport materials from the Attorney General; communications with Rebecca Strauss and Alejandra Contreras (and James Casteel) regarding "claw back" provision of Confidentiality Agreement in connection with apparent inadvertent disclosure of privileged materials to the Attorney General's office.

0.80

06/04/19 Ladene I. Mendoza Corresponded with Emily Zorn of USA Gymnastics and James Casteel and Alex Contreras from Miller Johnson regarding the Indiana Attorney General's request for 2019 misconduct files and corresponding U.S. Safe Sport Center communications; and gathered and collected additional e-mail responses sent to the Indiana Attorney General's office in response to an informal e-mail request and provided FileShare link to Rebecca Strauss with e-mail responses.

2.80

06/05/19 Mark D. Stuaan Communications with L. Mendoza and co-counsel regarding possible "claw back" of inadvertently disclosed privileged documents in productions to the Indiana Attorney General.

0.30

06/06/19 Mark D. Stuaan Participated in conference call with Rebecca Straus , Alejandra Contreras, James Casteel, Amy Murphy and L. Mendoza regarding status of review of documents for possible "claw back" for inadvertent disclosure of privileged documents in productions to the Indiana Attorney General.

0.50

06/06/19 Ladene I. Mendoza Prepared for and attended call with Miller Johnson regarding privilege documents to Indiana Attorney General's office.

0.70

06/07/19 Ladene I. Mendoza Corresponded with Mark Stuaan and James Casteel regarding safe sport materials requested from the Indiana Attorney General's office and having documents organized in subcategory of misconduct files in Relativity for future requests.

0.50

06/10/19 Mark D. Stuaan Communications with Christine Bowman, Gayle Littleton and Rebecca Strauss regarding background information about productions to the Attorney General in connection with responding to grand jury subpoena.

0.50

06/11/19 Mark D. Stuaan Participated in conference call with L. Mendoza, Rebecca Strauss, and Christine Bowman and Gayle Littleton regarding background information related to production of documents to the Indiana Attorney General's office in connection with preparing documents for response to grand jury subpoena.

1.00

06/11/19 Ladene I. Mendoza Prepared for and attended call regarding black mark redactions documents produced to the Indiana Attorney General's office.

1.00





06/13/19 Mark D. Stuaan Telephone conversation with C.J. Schneider regarding recent visit to the Indiana Attorney General by representatives of the Department of Justice and DOJ call to co-counsel regarding questions relating to documents produced to the Attorney General's office; communications with co-counsel regarding probable claw-back of inadvertently disclosed privileged documents regarding specific examples of documents and option regarding assertion of privilege; worked with L. Mendoza regarding cover letter for production of 2019 Safe Sport materials.

0.70

06/13/19 Ladene I. Mendoza Drafted production letter to the Indiana Attorney General's office regarding 2019 U.S. Center for SafeSport materials and misconduct files and sent to Mark Stuaan for review and comment.

0.50

06/14/19 Mark D. Stuaan Telephone conversation with Rebecca Strauss regarding request for assistance in identifying certain redacted documents produced to the Indiana Attorney General; communications with L. Mendoza regarding the same; considered message from L. Mendoza to Rebecca Strauss and James Casteel providing information relating to assisting in identifying various redacted documents provided to the Indiana Attorney General.

0.50

06/14/19 Ladene I. Mendoza Corresponded with Rebecca Strauss of Miller Johnson regarding documents with black mark redaction and summary of deposition materials from Georgia litigation with back mark redactions or missing exhibits.

2.70

06/20/19 Ladene I. Mendoza Reviewed additional SafeSport materials from 2019 and downloaded for uploading to Relativity; corresponded with James Casteel and Alex Contreras to add additional materials to Relativity.

1.70

06/24/19 Mark D. Stuaan Communication with L. Mendoza regarding an update on producing additional 2019 Safe Sport materials to the Indiana Attorney General.

0.10

06/26/19 Mark D. Stuaan Communications with Alejandra Contreras and L. Mendoza regarding status of review of documents for possible “claw back” and drafting of cover letter regarding the same.

0.20

06/27/19 Ladene I. Mendoza Drafted letter for production to the Indiana Attorney General's office and collected documents and materials for production; updated master timeline and production logs to include productions this month.

0.90

06/30/19 Mark D. Stuaan Considered message from Alejandra Contreras regarding draft of letter to Indiana Attorney General about claw-back notification; preliminarily reviewed draft of letter; communication to Alejandra Contreras, and others, about the draft letter and revised letter.

0.20





Other Charges:

Conference Call Charges Inv# 3172361313-061219 Moderator Ladene Mendoza Time of Call 9:27AM

13.30

$ 13.30




(317) 236-1313

Invoice 2242099













EXHIBIT H

Barnes & Thornburg LLP August 21, 2019 Invoice




(317) 236-1313

Invoice 2254794


August 21, 2019Mark D. Stuaan00075094-000001













(317) 236-1313





00075094-000001

INVESTIGATIONS

For legal services rendered in connection with the above matter for the period ending July 31, 2019 as described on the attached detail.







07/01/19 Mark D. Stuaan Reviewed draft of letter to the Indiana Attorney General’s office relating to “claw back” of inadvertently disclosed privileged documents; revised draft of letter; communications with Alejandra Contreras, Rebecca Strauss and L. Mendoza regarding revised draft of notification of “claw back” of inadvertently disclosed privileged documents.

0.70

07/02/19 Mark D. Stuaan Communication with L. Mendoza regarding request from Christine Bowman and Gayle Littleton for a conference call regarding background of production of documents to the Indiana Attorney General; telephone conversation with Christine Bowman and Gayle Littleton regarding the same; participated in conference call with Christine Bowman and Gayle Littleton regarding questions concerning background of document production to the Indiana Attorney General; communication with L. Mendoza following the conference call.

1.40

07/02/19 Ladene I. Mendoza Corresponding with Jenner Block attorneys regarding DOJ request for documents produced to the Indiana Attorney General's office.

0.40

07/10/19 Ladene I. Mendoza Prepared for and attended teleconference with Christine Bowman to discuss USA Gymnastics production to the Indiana Attorney General's office and redactions of documents.

0.90

07/22/19 Mark D. Stuaan Considered message form Deputy Attorney General requesting update on status of completing response to the CID; communication with L. Mendoza regarding status of the claw-back letter to the Attorney General’s office.

0.20

07/25/19 Mark D. Stuaan Communications with co-counsel regarding status of providing claw-back notification to the Attorney General’s office; reviewed revised draft of cover letter concerning the same and suggested revisions to the draft cover letter.

1.10

07/26/19 Mark D. Stuaan Communications with co-counsel and L. Mendoza regarding status of claw-back notice to the AG’s office and completion of response to the CID.

0.20

07/26/19 Ladene I. Mendoza Corresponded with M. Stuaan and Miller Johnson regarding USAG and Indiana Attorney General's requests; finalized requests for production narrative and sent to M. Stuaan for review and comment.

3.60

07/30/19 Mark D. Stuaan Considered messages from the Indiana Attorney General making requests for supplemental production for specific individuals and entities; communication with L. Mendoza and co-counsel regarding the same; reviewed draft of privilege log in connection with claw-back notice to the Indiana Attorney General; further work on finalizing responses to the RFPs, and communications with L. Mendoza regarding the same.

1.90

07/30/19 Ladene I. Mendoza Corresponding with Miller Johnson firm regarding fully and partially privileged production and corresponded regarding Indiana Attorney General's request for supplemental misconduct allegation material.

1.10





07/31/19 Mark D. Stuaan Communications with L. Mendoza and co-counsel regarding status of claw-back notice to the Indiana Attorney General; telephone conversation with Alejandra Contreras regarding the same; telephone conversation with C.J. Schneider regarding status of responses to requests for supplemental productions to the Indiana Attorney General.

2.20

07/31/19 Ladene I. Mendoza Reviewed and analyzed Relativity document search related to Indiana Attorney General's supplemental request for misconduct allegation materials regarding USA Gymnastics' members.

2.70





(317) 236-1313

Invoice 2254794













EXHIBIT I

Barnes & Thornburg LLP September 18, 2019 Invoice




(317) 236-1313

Invoice 2264318


September 18, 2019Mark D. Stuaan00075094-000001













(317) 236-1313





00075094-000001

INVESTIGATIONS

For legal services rendered in connection with the above matter for the period ending August 31, 2019 as described on the attached detail.







08/01/19 Mark D. Stuaan Communications with L. Mendoza regarding Attorney General’s request for supplemental production of documents relating to various individuals and ; considered communication from Alejandra Contreras regarding a summary of her review of documents relating to in connection with request for supplemental production by the Attorney General’s office regarding ; communication with co-counsel regarding status of notice to the Attorney General’s office regarding notice of claw-back of inadvertently disclosed privileged materials.

0.60

08/02/19 Mark D. Stuaan Communications with L. Mendoza regarding status of compiling documents in response to two requests from the Attorney General’s office for supplemental production of responsive documents; participated in conference call with Miller Johnson and Jenner Block regarding background information relating to review of documents for potential claims of privilege or work-product protection, relating to notice of claw-back to the Attorney General’s office and possible inadvertent disclosure of privileged materials during the course of productions to the Attorney General’s office, including notice to the Attorney General’s office concerning the claw-back and substitution of redacted or partially redacted documents in lieu of inadvertently disclosed privileged materials; participated in call to the Deputy Attorney General, with L. Mendoza, to provide preliminary notice of intent to give notice of inadvertent disclosure of privileged materials and the Attorney General’s view that other documents previously produced have been redacted beyond what appears to be legitimate assertions of the attorney-client privilege or work product protection; telephone conversation with Alejandra Contreras following the telephone conversation with the Deputy Attorney General, and email to Alejandra, Rebecca Strauss and James Casteel regarding the same.

2.30

08/05/19 Mark D. Stuaan Participated in conference call with co-counsel regarding review of documents withheld from the Indiana Attorney General's office on claims of attorney/client privilege and/or work product protection; communication with L. Mendoza regarding status of various productions to the Attorney General's office.

1.50

08/05/19 Ladene I. Mendoza Corresponding with Daniel Campbell regarding supplemental request from the Indiana Attorney General's office.

0.60

08/05/19 Ladene I. Mendoza Prepared for and attended teleconference with Miller Johnson regarding privileged documents related to the Indiana Attorney General's office; reviewed and analyzed previous emails to provide context on privilege previously done; and corresponded with J. Casteel of Miller Johnson related to search compiled on Relativity database for supplemental request from the Indiana Attorney General's office

2.40





08/05/19 Ladene I. Mendoza Corresponded with D. Campbell of USA Gymnastics to follow up on documents sent regarding the Indiana Attorney General's supplemental request to determine if all attached documents referenced in the misconduct materials were provided.

0.50

08/07/19 Mark D. Stuaan Considered message from the Deputy Attorney General regarding questions relating to assertion of attorney-client privilege and/or work product protection in prior productions, as well as apparent inadvertent disclosure of privileged and/or protected documents; communications with co-counsel regarding the same; responded to the Deputy Attorney General’s email; telephone conversation with Alejandra Contreras regarding messages from and to the Deputy Attorney General; considered draft plan for review of documents relating to the Deputy Attorney General’s questions concerning claims of attorney-client privilege and/or work product protection, and review of documents relating to anticipated claw-back notice to the Attorney General’s office.

1.30

08/07/19 Ladene I. Mendoza Correspondence with D. Campbell of USA Gymnastics and A. Contreras of Miller Johnson related to supplemental production and requests received from the Indiana Attorney General's office; drafted summary of documents previously marked responsive related to the Indiana Attorney General's office supplemental request where issues of privilege or redactions existed; correspondence with J. Casteel regarding additional documents received from USA Gymnastics to add to Relativity database and request for production of these documents.

3.30

08/08/19 Mark D. Stuaan Communications with Alejandra Contreras and L. Mendoza regarding production of documents relating to ; communications with Alejandra Contreras and others relating to Bates numbers of various documents listed by the Indiana Attorney General as documents for which they had questions about redactions for attorney/client privilege and/or work product.

0.30

08/08/19 Ladene I. Mendoza Corresponded with A. Contreras of Miller Johnson regarding supplemental request from the Indiana Attorney

General's office regarding documents to review and mark responsive based on the supplemental request received.

0.50

08/13/19 Mark D. Stuaan Considered message form Alejandra Contreras responding to questions raised by the Attorney General’s office concerning documents provided in fully or partially redacted form based on claims of attorney-client privilege and work product protection; responded to the message from Alejandra Contreras.

0.80

08/15/19 Mark D. Stuaan Communications with colleagues and co-counsel regarding status of producing documents in response to supplemental requests from the Indiana Attorney General's office.

0.10





08/16/19 Mark D. Stuaan Communications with co-counsel and colleagues regarding upcoming productions to the Indiana Attorney General's office and related matters.

0.30

08/16/19 Ladene I. Mendoza Corresponding with A. Contreras on production of documents to Indiana Attorney General's office in order to ensure all documents collected are produced.

0.60

08/19/19 Mark D. Stuaan Communications with L. Mendoza and co-counsel regarding various topics, including questions related to prior productions made to Ropes & Gray (including review of records regarding such productions) and upcoming productions in connection with supplemental requests from the Indiana Attorney General's office.

1.50

08/19/19 Ladene I. Mendoza Review of requests from Miller Johnson on deposition materials to Ropes and Grey and other additional materials; review of production to Indiana Attorney General regarding overly claimed privilege documents and review of previous Faegre productions requested from Miller Johnson.

6.20

08/20/19 Mark D. Stuaan Communication with L. Mendoza regarding status of spreadsheets providing cross reference Bates numbers for various documents questioned by the Attorney General's office as to the assertion of privilege or protection.

0.10

08/20/19 Ladene I. Mendoza Corresponding with Amy Murphy of Miller Johnson regarding productions to Indiana Attorney General cross-reference spreadsheet and providing summary regarding the same.

1.50

08/20/19 Ladene I. Mendoza Drafting production letter for supplemental request from Indiana Attorney General's office and reviewed documents in production in order to ensure claw back and over redacted material in letter was stated correctly in cover letter.

2.70

08/21/19 Mark D. Stuaan Communications with Amy Murphy confirming transmittal of June 8 Chris Tebo letter to the Indiana Attorney General's office; worked on letter for upcoming production to the Attorney General's office; communication with L. Mendoza regarding upcoming production to the Attorney General's office.

0.80

08/21/19 Ladene I. Mendoza Revising production letter after M. Stuaan comments and notes and corresponding with Alex Contreras and Rebecca Strauss of Miller Johnson on privilege and claw back mentioned in the letter; corresponding with James Casteel of Miller Johnson regarding spreadsheet with redactions.

0.90

08/23/19 Mark D. Stuaan Communication with Rebecca Strauss regarding draft of cover letter for upcoming production to the Indiana Attorney General's office; worked on draft of communication to the Indiana Attorney General's office regarding questions related to the list provided by that office on August 7 relating to the assertion of attorney-client privilege and/or work production protection, including review of communications with co-counsel and communications with co-counsel and colleagues regarding the same.

1.10





08/26/19 Mark D. Stuaan Communication with Rebecca Strauss regarding upcoming production to the Indiana Attorney General's office and draft of cover letter for that production.

0.10

08/27/19 Mark D. Stuaan Communications with Amy Murphy regarding questions relating to production of specific documents to the Indiana Attorney General's office; reviewed file materials relating to same including history of productions of documents to the Indiana Attorney General's office and to various other entities; communications with L. Mendoza regarding the same; communications with Rebecca Strauss regarding upcoming production to the Indiana Attorney General's office and related aspects of that production.

3.30

08/27/19 Ladene I. Mendoza Reviewed and analyzed request regarding previous production and reviewing correspondence regarding Indiana Attorney General's list of privileged documents.

5.70

08/28/19 Mark D. Stuaan Drafted communication to the Indiana Attorney General's office concerning questions relating to the list of documents which the Attorney general's office provided regarding assertions of attorney-client privilege and/or work product protection; communications with co-counsel regarding various topics.

0.50

08/28/19 Ladene I. Mendoza Finalized document production to Indiana Attorney General's office; and drafted correspondence regarding other prefix bates numbers in Indiana Attorney General's list of privileged or concerning documents

1.80

08/29/19 Mark D. Stuaan Communications with C.J. Schneider regarding status of developing privilege log in connection with productions to the Indian Attorney General's office and the Department of Justice (in response to subpoena); reviewed terms of the Confidentiality Agreement with the Attorney General's office as well as the instructions related to the civil investigative demand regarding providing a privilege log in connection with productions in response to the civil investigative demand; communication to C.J. Schneider regarding the provisions in the Confidentiality Agreement and the civil investigative demand regarding a privilege log and possible impact on developing a "categorical" privilege log; communications with Rebecca Strauss regarding delivery of devices collected by Miller Johnson from USAG and storage of same at B&T; communications with Rebecca Strauss regarding the inventory for the devices collected by Miller Johnson.

1.80

08/29/19 Ladene I. Mendoza Updated production log, master timeline and corresponding with Alex Contreras on files to store at B&T.

1.00





08/30/19 Mark D. Stuaan Prepared for conference call with co-counsel regarding development of a privilege log, including previous communications with the Indiana Attorney General's office relating to production of a privilege log and most recent production to that office; participated in conference call with C.J. Schneider, Rebecca Strauss, Gayle Littletona and Keri Holleb.

2.20

08/30/19 Ladene I. Mendoza Corresponding with J. Casteel of Miller Johnson to provide copy of Indiana Attorney General production letters after reviewing and locating letters and providing a summary of background information for previous production letters.

1.00





(317) 236-1313

Invoice 2264318













EXHIBIT J

Barnes & Thornburg LLP October 16, 2019 Invoice




(317) 236-1313

Invoice 2274179


October 16, 2019Mark D. Stuaan00075094-000001













(317) 236-1313





00075094-000001

INVESTIGATIONS

For legal services rendered in connection with the above matter for the period ending September 30, 2019 as described on the attached detail.







09/04/19 Mark D. Stuaan Participated in conference call with C.J. Schneider and Catherine Steege regarding upcoming meeting with representatives of the Indiana Attorney General's office on September 6; communication with USAG counsel regarding the federal grand jury subpoena and potential submission of categorical privilege log; communication with USAG bankruptcy counsel regarding upcoming meeting with the Indiana Attorney General's office.

0.70

09/05/19 Mark D. Stuaan Communications with co-counsel and the Deputy Attorney General regarding scope of the upcoming meeting; communications with C.J. Schneider and Catherine Steege regarding communications with the Deputy Attorney General; communications with co-counsel and the Deputy Attorney General regarding attendees for the meeting.

0.50

09/06/19 Mark D. Stuaan Conferred with C.J. Schneider, Catherine Steege and Melissa Root prior to update meeting with representatives of the Indiana Attorney General's office; attended meeting with representatives of the Indiana Attorney General's office regarding updates on various topics and remarks by Li Li Leung regarding status of USAG and changes made, and potential changes, to USAG organization, policies and procedures; conferred with C.J. Schneider, Catherine Steege and Melissa Root following the meeting about th meeting and possible future meetings.

2.70

09/09/19 Mark D. Stuaan Checked statutes relating to civil investigative demands issued by the Indiana Attorney General for possible statutory obligation to update productions in response to a civil investigative demand; reviewed the CID for language relating to an obligation to update production of documents; communication to C.J. Schneider regarding the same and possible strategy for going forward on producing updated documents; considered message from Rebecca Strauss regarding review of documents possibly subject to the "claw back" provision of the Confidentiality Agreement; responded to email from Rebecca Strauss.

1.40

09/11/19 Mark D. Stuaan Communications with co-counsel regarding upcoming interview of Rachel Brazos; communication to C.J. Schneider regarding duty to update production of documents to the Indiana Attorney General's office.

0.40

09/11/19 Ladene I. Mendoza Corresponding with M. Stuaan after searching and reviewing production letters and email communications with USAG to determine cut off date of 2019 materials last sent to the Indiana Attorney General's office.

1.00

09/12/19 Mark D. Stuaan Communications with Phil Hilder regarding upcoming interview of Rachel Brazos.

0.10

09/13/19 Mark D. Stuaan Communications with co-counsel regarding collected electronic devices and categorical privilege log; telephone conversation with C.J. Schneider regarding the same.

0.50





09/16/19 Mark D. Stuaan Telephone conversation with co-counsel regarding questions relating to review of documents in connection with "claw back" of materials.

0.20





(317) 236-1313

Invoice 2274179













EXHIBIT K

Barnes & Thornburg LLP November 25, 2019 Invoice




(317) 236-1313

Invoice 2287641


November 25, 2019Mark D. Stuaan00075094-000001













(317) 236-1313





00075094-000001

INVESTIGATIONS

For legal services rendered in connection with the above matter for the period ending October 31, 2019 as described on the attached detail.







10/04/19 Mark D. Stuaan Communications with Rebecca Strauss and L. Mendoza regarding delivery of several electronic devices collected by Rebecca Strauss from USAG on October 4.

0.20

10/08/19 Mark D. Stuaan Communication to Rebecca Strauss requesting update on inventory of electronic devices collected at USAG by Miller Johnson on October 4.

0.10

10/10/19 Mark D. Stuaan Communication to Deputy Attorney General requesting update on request for acceptance of categorical privilege log; participated in conference call with Rebecca Strauss, Gayle Littleton, Keri Holleb Hotaling and Laura Pelanek regarding status of review of documents related to claw-back and to discuss handling of USAG personnel emails with personal attorneys.

0.50

10/11/19 Mark D. Stuaan Communications with co-counsel regarding handling of emails between USAG personnel and personal attorneys, including telephone conversation with and

; communication with Rebecca Strauss regarding inventory for electronic devices gathered on October 4; communication with co-counsel regarding status of contact with Indiana Attorney General's office regarding status of document review in connection with claw-back of documents and handling of communications between USAG personnel and personal attorneys.

0.90

10/14/19 Mark D. Stuaan Participated in conference call with co-counsel regarding various topics, including USAG personnel communications with personal counsel and the Department of Justice's request to make mirror images of various electronic devices from USAG; call to Deputy Attorney General regarding retrieval of USAG personnel communications with personal attorneys (left message).

1.10

10/17/19 Mark D. Stuaan Reviewed draft of letter from to the Walker County District Attorney regarding search terms; communication to

and other co-counsel regarding comments concerning the draft letter; checked inventory of items collected from USAG by Miller Johnson (delivered to B&T October 4, 2019); communication to Rebecca Strauss regarding review of inventory of Box 15 and related questions.

1.10

10/18/19 Mark D. Stuaan Telephone conversation with Deputy Attorney General relating to USAG personnel communications with personal counsel and handling of those documents; communications with co-counsel concerning the same.

0.50





10/21/19 Mark D. Stuaan Considered letter from to the Walker County District Attorney; communications with co-counsel regarding communication with Attorney General's office relating to claw-back of documents; participated in conference call with co-counsel regarding various investigations and the status of those investigations; call to Deputy Attorney General regarding cost for retrieval of USAG personnel and communications with personal counsel.

1.20

10/22/19 Mark D. Stuaan Communications with co-counsel regarding federal government imaging of various devices from USA Gymnastics.

0.20

10/23/19 Mark D. Stuaan Communications with the Indiana Attorney General's office regarding handling of emails between USAG personnel and the personal counsel; communications with co-counsel regarding the same.

0.80

10/28/19 Mark D. Stuaan Participated in conference call with co-counsel regarding status of various investigations; call to Deputy Attorney General in follow up to question regarding USAG personnel communications with personal counsel.

0.70

10/30/19 Mark D. Stuaan Communications with co-counsel regarding receipt of “pin drive” from QDiscovery and placement of “pin drive” in storage with other devices; telephone conversation with Deputy Attorney General regarding handling of USAG personnel communications with personal attorneys; communication with co-counsel regarding proposal of language for the Indiana Attorney General’s office to consider; communication to Deputy Attorney General regarding proposed language.

0.60

10/31/19 Mark D. Stuaan Message to co-counsel about imaging of USAG electronic devices in November by federal authorities.

0.10





(317) 236-1313

Invoice 2287641













EXHIBIT L

Barnes & Thornburg LLP December 31, 2019 Invoice




(317) 236-1313

Invoice 2301617


December 31, 2019Mark D. Stuaan00075094-000001













(317) 236-1313





00075094-000001

INVESTIGATIONS

For legal services rendered in connection with the above matter for the period ending November 30, 2019 as described on the attached detail.








11/01/19 Mark D. Stuaan Phone conversation with L. Mendoza regarding status of claw-back and upcoming device imaging.

0.20

11/05/19 Mark D. Stuaan Communication with W. Asbury concerning receipt of additional hard drives for imaging by the Government; communication with co-counsel regarding the same.

0.10

11/08/19 Mark D. Stuaan Considered messages from co-counsel regarding upcoming imaging of USAG electronic devices by Government.

0.10

11/11/19 Mark D. Stuaan Communications with co-counsel regarding status of upcoming imaging of various devices on November 12; and status of claw-back of some documents.

0.50

11/12/19 Mark D. Stuaan Conferred with Rebecca Strauss, Laura Pelanek and Keri Holl-Hotaling regarding upcoming imaging of various devices by the Government pursuant to subpoena; communications with Rebecca Strauss, Keri Holl-Hotaling and Laura Pelanek regarding questions and issues related to the imaging of devices; communications with Mike Johnson, HSI Forensics, regarding imaging of devices; conferred with Rebecca Strauss, Laura Pelanek and Keri Holl-Hotaling following first day of imaging of devices.

1.40

11/14/19 Mark D. Stuaan Communications with Laura Pelanek regarding imaging of various electronic devices from USAG; communications with Mike Johnson and Robert Clegg, HSI, regarding same, and Laura Pelanek, regarding status of imaging and anticipated completion of imaging.

0.90

11/15/19 Mark D. Stuaan Communications with Laura Pelanek regarding completion of imaging and return of items to secure storage, and return of some items (laptops) to USAG.

0.20

11/18/19 Mark D. Stuaan Participated in conference call with co-counsel regarding status of various investigations.

0.50

11/20/19 Mark D. Stuaan Communication with L. Mendoza regarding status of November 11 secure file transfer to the Indiana Attorney General's office; communication to co-counsel regarding the same.

0.40

11/21/19 Mark D. Stuaan Communication with co-counsel regarding status of obtaining copies of the mirror images of electronic devices made by HSI.

0.10

11/25/19 Mark D. Stuaan Follow up communication to the Indiana Attorney General regarding November 11 secure file transfer and "claw back" of previously inadvertently disclosed privileged materials.

0.10

11/26/19 Mark D. Stuaan Considered response from the Indiana Attorney General's office regarding secure file transfer on November 11; communication to co-counsel regarding the same.

0.10

11/27/19 Mark D. Stuaan Considered message from Deputy Attorney General regarding status of destruction of previously provided privileged documents which were inadvertently disclosed (claw-back); communication to C.J. Schneider regarding the same; communication to co-counsel regarding message from the Deputy Attorney General regarding the claw-back of documents.

0.20





Other Charges:


$ 10.00




(317) 236-1313

Invoice 2301617













EXHIBIT M

Barnes & Thornburg LLP January 21, 2020 Invoice




(317) 236-1313

Invoice 2306182















(317) 236-1313





00075094-000001

INVESTIGATIONS

For legal services rendered in connection with the above matter for the period ending December 31, 2019 as described on the attached detail.







12/03/19 Mark D. Stuaan Participated in conference call with c-counsel regarding status of various investigations.

1.10

12/09/19 Mark D. Stuaan Participated in Investigations conference call regarding status of various investigations.

0.50

12/16/19 Mark D. Stuaan Communication with Alejandra Contreras regarding information collected by counsel in USAG Drop Box; participated with co-counsel in weekly call concerning updates on various investigations.

0.80

12/23/19 Mark D. Stuaan Communication with Keri Holleb-Hotaling and Leslie King prior to interview of Leslie King; communication with Leslie King following her interview regarding her USAG cell phone; communication to Keri Holleb -Hotaling and Laura Pelanek regarding King's cell phone.

0.20





(317) 236-1313

Invoice 2306182













EXHIBIT N

Barnes & Thornburg LLP February 25, 2020 Invoice




(317) 236-1313

Invoice 2317787















(317) 236-1313





00075094-000001

INVESTIGATIONS

For legal services rendered in connection with the above matter for the period ending January 31, 2020 as described on the attached detail.







01/03/20 Mark D. Stuaan Telephone conversation with Deputy Attorney General Weaver regarding possibly responsive documents in Drop Box.

0.10

01/09/20 Mark D. Stuaan Communications with C.J. Schneider regarding storage of cell phone and two laptops from Leslie King.

0.10

01/13/20 Mark D. Stuaan Participated in conference call regarding status of various investigations and related topics.

0.60

01/16/20 Mark D. Stuaan Communications with co-counsel and USAG staff regarding Indiana Attorney General's request for supplemental production relating to Safe Sport materials; telephone conversation with Keri Hotlieb-Hotaling and Laura Pelanek regarding Indiana Attorney General's request for supplemental production of Safe Sport materials.

0.40

01/22/20 Mark D. Stuaan Communications with co-counsel regarding upcoming production of documents previously withheld from production based on privilege; communication with L. Mendoza regarding the same.

0.40

01/24/20 Mark D. Stuaan Communication with Rebecca Strauss regarding updating the inventory of electronic devices held by B&T; communication with co-counsel regarding compilation of Safe Sport documents for supplemental production to the Indiana Attorney General.

0.30

01/27/20 Mark D. Stuaan Communications with Rebecca Strauss regarding update of inventory of electronic devices; communications with co-counsel regarding status of compiling additional Safe Sport materials for production to the Indiana Attorney General.

0.20





(317) 236-1313

Invoice 2317787











