GUTRIDESAFIERREESELLP MichaelR. Reese(Cal. State BarNo. …securities.stanford.edu/filings-documents/1035/WFC05_01/... · 2007-12-21 · 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17

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GUTRIDE SAFIER REESE LLPMichael R. Reese (Cal. State Bar No. 206773)Kim E. Richman (admitted pro hac vice)230 Park Avenue, Suite 963New York, New York 10169Telephone: (212) 579-4625Facsimile: (212) 253-4272

- and -

GUTRIDE SAFIER REESE LLPAdam J. Gutride (Cal. State Bar No.181466)Seth A. Safier (Cal. State Bar No. 197427)835 Douglass StreetSan Francisco, California 94114Telephone: (415) 271-6469Facsimile: (415) 449-6469

Court Appointed Lead Counsel

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

RONALD SIEMERS and FORRESTMCKENNA, Individually And On Behalf Of AllOthers Similarly Situated,

Plaintiff,

vs.

WELLS FARGO & COMPANY, WELLSFARGO INVESTMENTS, LLC, WELLS FARGOFUNDS MANAGEMENT, LLC, WELLSCAPITAL MANAGEMENT INC., STEPHENSINC., WELLS FARGO FUNDS DISTRIBUTOR,LLC, and WELLS FARGO FUNDS TRUST,

Defendants.

Case No. 05-04518 WHA

DECLARATION OF ADAM J.GUTRIDE IN SUPPORT OFPLAINTIFF'S MOTION FOR AWARDOF ATTORNEYS' FEES ANDEXPENSES

DATE: JANUARY 31, 2008TIME: 8:00 AMCTRM: 9, 19TH FLOORJUDGE: JUDGE WILLIAM H. ALSUP

Declaration of Adam J. Gutride Re Plaintiff s Motion for Award of Attorneys' Fees and Expenses

Case No.: 05-cv-04518 (WHA)

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I, Adam J. Gutride, do hereby declare the following:

1. I am a member of the Bar of this Court and a partner in the firm of Gutride Safier

Reese LLP, Court-appointed class counsel. I make this declaration of my own personal knowledge.

2. I have reviewed the timesheets prepared by the attorneys and legal assistants

employed by my firm in connection with this case . Attached hereto as Exhibits A through D are

charts showing the hours worked those persons on this case . Exhibit A shows totals by timekeeper,

their hourly rates and total lodestar . Exhibit B shows details with respect to work performed on

each court filing. Exhibit C shows details with respect to work performed in discovery. Exhibit D

shows details with respect to other work performed.

3. I have reviewed the expenses incurred by this firm to prosecute this case. Attached

hereto as Exhibit E is a chart of those expenses. Included in the chart are travel expenses that this

firm advanced for the lead plaintiffs to come to San Francisco for hearings and deposition.

4. The charts attached hereto do not include the additional hours Class Counsel will

spend preparing for and attending the final approval hearing, addressing shareholder opt-outs and

objections, and consulting with the claims administrator to facilitate settlement administration. I

anticipate that this work will take an additional 30 to 50 hours, assuming there are no appeals from

the judgment.

I declare under penalty of perjury under the laws of the United States that the foregoing is

true and correct. Executed this 21st of December, 2007 in San Francisco, California.

/s/ Adam J. GutrideADAM J. GUTRIDE

Declaration of Adam J. Gutride Re Plaintiff s Motion for Award of Attorneys' Fees and Expenses 2

Case No.: 05-cv-04518 (WHA)

EXHIBIT A

Summary of all hours-Gutride Safier Reese LLP

TIMEKEEPER TOTAL HOURS RATE TOTALAJG 762.25 $475.00 $362,068.75MRR 852.25 $525.00 $447,431.25SAS 493.25 $450.00 $221,962.50KER 85.5 $325.00 $27,787.50KJS 15.75 $375.00 $5,906.25JPM 113.75 $375.00 $42,656.25EJM 208.5 $375.00 $78,187.50

TOTAL 2531 .25 $1,186,000.00

EXHIBIT B

Pleadings, Hearings

Draft, Edit Class Action Complaint

Summonses

Review ADR Scheduling Order, Supplemental OrderTo Order Setting Initial Case ManagementConference; Standing Order For Early Notice To ClassMembers In Federal Securities Cases; Clerk's NoticeRe: Failure To E-File And/Or Failure To Register AsAn E-Filer; Notice Of Appearance By Bruce A.Ericson

Review, Edit Stipulation And [Proposed] SchedulingOrder; Order Approving Same

Draft, Confer With Client Regarding Motion ToAppoint Lead Plaintiff And Lead Counsel Filed ByThe McDaniel Family Trust; Proposed Order ReSame; Declaration Of Seth A. Safier In Support

Review, Edit Stipulation And [Proposed] Order ToContinue Case Management Conference And RelatedDates)

Date TimekeeperFiled orComp-leted AJG MIRR SAS KER KJS JPM EJM

1

1

1

C

C

11/04/05 3.5

Date Timekeeper

Pleadings, Hearings Filed orComp-leted AJG MRR SAS KER KJS JPM EJM

Review Motion For Leave To Appear In Pro Hac Vice, 01/27/06Janine L. Pollack, Esq., Steven G. Schulman, Esq.,Jerome Congres

Review Order Denying Stipulation To Cancel Case 01/30/06 .25Management Conference

Review Statement Of Non-Opposition Re: Motion For 02/02/06 .25Appointment Of Lead Plaintiff And Lead Counsel

Review Joint Case Management Statement, Rule 02/02/06 .2526(F) Report And [Proposed] Order Filed ByDefendants

Draft, Edit Certificate Of Counsel By Seth A. Safier 02/06/06On Behalf Of The McDaniel Family Trust

Draft, Edit Certificate Of Counsel Adam Gutride By 02/06/06 .25Seth A. Safier On Behalf Of The McDaniel FamilyTrust

Review Certificates Of Other Counsel 02/06/06 .25

Review Scheduling Order. 02/09/06 .25

Prepare For, Attend Initial Case Management 02/09/06Conference

Review Order Re Lead-Plaintiff Questionnaire. 02/10/06 .25

.25

.25

.25

.25

.25

.,75

.25

.25

2.0

.25

Pleadings, Hearings

Review Clerk's Notice Rescheduling Motion Hearing.

File Summons Returned Executed By The McDanielFamily Trust.

Review, Confer With Client Re Motion To AppointLead Plaintiff And Lead Counsel Revised Notice OfMotion To Appoint Ronald Siemers As Lead Plaintiff,Approval Of Lead Plaintiffs Selection Of LeadCounsel, And Memorandum Of Points AndAuthorities In Support Thereof, SupportingDeclaration Of Reese

Review Defendants' Response To Court's QuestionsRe: Appointment Of Lead Plaintiff And Lead Counsel

Review Corrected Revised Notice Of Motion ToAppoint Ronald Siemers As Lead Plaintiff, ApprovalOf Lead Plaintiffs Selection Of Lead Counsel, AndMemorandum Of Points And Authorities In SupportThereof And Declaration

Review Minute Entry Re Motion To Appoint LeadPlaintiff And Lead Counsel


02/14/06 .25

02/16/06 .25

02/16/06 .25 .75

02/16/06 .25 .5

02/21/06 .5

02/23/06 .25 .25

Date Timekeeper


Review Order By Judge Alsup Granting In Part And 02/28/06 .25 .5Denying In Part Motion To Appoint Lead PlaintiffAnd Lead Counsel

Review Order Correcting Lead-Plaintiff Deadlines 03/01/06 .25

Review Affidavit Certification Of Lead Plaintiff 03/08/06 .25Ronald Siemers By The McDaniel Family Trust.

Review Declaration Of Court Appointed Lead Plaintiff 03/09/06 .25 .25Ronald Siemers Re: Choice Of Lead Counsel Filed ByRonald Siemers . Filed Under Seal

Review Order Approving Selection Of Class Counsel.. 03/14/06 .25 .25

Pleadings, Hearings

Review Filings During Time That Milberg Weiss WasLead Counsel (Dockets 59-97), Including:• Amended Complaint• Summons To Wells Fargo Funds Distributor• Letter From Bruce Ericson, 4/24/06• Letter From Lead Counsel Re Lifting Discovery

Stay, 4/24/06• Defendant's Motions To Dismiss And Motion To

Strike, Requests For Judicial Notice, Exhibits• Defendants' Opposition To Motion To Compel• Transcript Of Discovery Hearing• Plaintiff's Opposition To Motions To Dismiss And

Strike, Declarations Of Siemers And Reese InSupport, Request For Judicial Notice

• Plaintiffs' Motion To Strike• Defendants' Opposition To Plaintiffs' Motion To

Strike• Defendants' Replies In Support Of Motions To

Dismiss And Strike• Transcript Of Proceedings Held On 02/23/06

Review Order Re Lead Counsel.

Review Response and Declaration Of Michael R.Reese To June 8, 2006 Court Order Re Lead Counsel


04/11/06 4.5 5

06/08/06 .25 .25

06/12/06 .75 .5

Date Timekeeper


Review Order For Further Briefing On Defendants' 06/13/06 .25 .25Motion To Strike. Signed By Judge Alsup On 6/13/06.

Review Plaintiffs Brief In Response To The Court's 06/15/06 .25 .25June 13, 2006 Order For Further Briefing On TheTimeliness Of Defendants' Motion To Strike ByRonald Siemers.

Review Brief (Supplemental) In Support Of 06/15/06 .25 .25Defendants' Motion To Strike References To ConsentDecrees In Plaintiffs Consolidated Amended ClassAction Complaint Filed By All Defendants.(Filed On6/15/2006) Modified On 6/19/2006

Review Statement Of Recent Decision Pursuant To 06/16/06 .25 .25Civil Local Rule 7-3.D Filed By All Defendants.

Review Order Requesting Comment For June 21 06/20/06 .25 .25Hearing.

Review Response To Order Requesting Comment By 06/21/06 .25 .25All Defendants.

Draft, Edit Plaintiffs Response To June 20, 2006 Court 06/21/06 .75 2Order Requesting Comment By Ronald Siemers.

Attend Motion Hearing Held On 6/21/2006 Re 06/21/06 2 2Motions To Dismiss, Strike

Date Timekeeper


Review ORDER. 06/26/06 .25 .251 1 1 1

Participate In ADR Phone Conference 06/26/06 .25

Draft, Edit Ex Parte Declaration Of Michael Reese In 06/29/06 1Response To June 26 Court Order To Counsel MichaelReese (Redacted) By Ronald Siemers.

Review Order Approving Change Of Lead Counsel. 06/30/06 .25 .25 .25Signed By Judge Alsup On 6/30/06.


Review Order Granting In Part And Denying In Part 08/14/06 .5 .5 .5 .5Motions To Dismiss, Strike

Draft, Edit, Confer With Client Re Second Amended 08/31/06 2.5 33.5 1 .75Complaint


Review Clerk's Notice Scheduling Case Management 09/11/06 .25 .25Conference

Draft, Edit [Proposed] Order Re Request For 09/14/06 .5Continuance Of Case Management Conference

Pleadings, Hearings

Review Defendants' Motion To Dismiss Plaintiff sSecond Amended Consolidated Class ActionComplaint, Request For Judicial Notice, ProposedOrder


Review Stipulation And Order Continuing Case 0Management Conference And Related Dates.

Review Defendants' Amended Motion To Dismiss 0Plaintiffs' Second Amended Consolidated Class ActionComplaint, Errata Re Same

Review Joint Case Management Statement Filed By 0All Defendants.

Review Case Management Scheduling Order: Order 0Referring Case To Magistrate Judge Elizabeth D.Laporte For Mediation/Settlement. Order Lifting Stay.

Draft, Edit Memorandum In Opposition Re Motion To 0Dismiss Plaintiffs Second Amended ConsolidatedClass Action Complaint, Declaration Of MichaelReese, Request For Judicial Notice

Prepare For, Attend Initial Case Management 0Conference (includes travel from NYC to SF forMRR)

09/14/06 2. 0 3. 0 . 50

Date Timekeeper


Review Order Rescinding Reference And Making New 10/02/06 25Order Of Reference To Magistrate Judge Spero ForMediation/Settlement.

Review Transcript Of Proceedings Held On 06/21/06 1

Review Order Reassigning Case. To Judge Joseph C. 1Spero For All Further Proceedings.

Participate In Telephone Conference To Discuss 10/04/06Possible Dates For Settlement Conference.

Review Defendants' Reply In Support Of Motion To 1Dismiss Plaintiffs' Second Amended ConsolidatedClass Action Complaint

Draft, Edit Letter From Lead Counsel For Plaintiff 1Regarding Proposed Case Management Order No. 2Modifying Deadline For Seeking Leave To AddParties Or Claims.

Review Notice Of Settlement Conference And 1Settlement Conference Order.

Review Notice Re October 19, 2006 Argument. 1

Review Notice Of Substitution Of Counsel By Patricia 1J. Medina

0/02/06 .25 .25 .25

0/03/06 .25 .25

0/04/06 .5

0/05/06 .5 2.5 .5

0/10/06 .75

0/11/06 .25 .25

0/17/06 .25 .25 .25

0/17/06 .25 .25 .25

Date Timekeeper


Draft, Edit Stipulation And [Proposed] Order Re Initial 10/17/06 .5Disclosures (Fed.R.Civ.P.26(A)(1))

Review Order Approving Stipulation And Order Re 10/19/06 .25Initial Disclosures

Prepare For, Attend Motion Hearing On 10/19/2006 10/19/06 3.5 26 4Before William Alsup Re Motion To DismissPlaintiffs Second Amended Consolidated Class ActionComplaint, (includes travel from NYC to SF for MRR)

Review Order Granting In Part And Denying In Part 10/24/06 .5 .5 .5 .5Motion To Dismiss

Draft, Edit Stipulation And [Proposed] Order To 10/25/06 .25 .25Modify Briefing Schedule On Motion For ClassCertification By Ronald Siemers.

Review Order Approving Stipulation And Order To 10/26/06 .25 .25 .25Modify Briefing Schedule On Motion For ClassCertification

Draft, Edit Motion For Leave To Appear In Pro Hac 10/26/06 1 .25 .75Vice, Kim E. Richman, Esq.,

Review Order By Judge William Alsup Granting 10/31/06 .25Motion For Pro Hac Vice Of Kim E. Richman.

Pleadings, Hearings

Edit Stipulation Extending Time For InterrogatoryResponses And Objections By Wells Fargo &Company, Broker-Dealer Defendants.

Edit Stipulation Extending Time For Responses ToRequests For Production By Wells Fargo & Company,Broker-Dealer Defendants.

Draft, Edit First Motion To Amend/Correct SecondAmended Complaint Filed By Ronald Siemers,Declaration Of Michael Reese.

Review Order Re Letter OfNovember 27, 2006.

Review Scheduling Order Regarding Any Motion ToRecuse Or To Disqualify Judge.

Review Fund Defendants' Memorandum InOpposition To Plaintiffs' Motion For Leave To FileThird Amended Complaint

Review Unopposed Administrative Motion OfDefendants To File Document Under Seal; AndSupporting Declaration, Proposed Order


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1

11/09/06 . 25 . 5

Date Timekeeper


RPviPw RrnkPr T)Pa1Pr T)PfPnd ntc ' MPmnrnndiim Tn 1 7/n7/nh 75

Opposition To Plaintiffs Motion For Leave To FileThird Amended Complaint, Declaration Of CaseyGriffin, Jacqueline Chan, Linsey Stuckey, ProposedOrder

Review Transcript Of Proceedings Held On 10/19/06 1

Draft/Edit Reply To Opposition Re First Motion To 1Amend/Correct Second Amended Complaint,Declarations Of Joyce Kulasxa, Guinn Eiland, AlanRobbins

Draft, Edit, Negotiate Proposed Stipulated Protective 1Order No. 1

Review Clerk's Notice Continuing Motion Hearing 1

Review Order Approving Stipulated Protective Order 1Subject To Stated Conditions

Review Request Re Wells Fargo Funds. Signed By 1Judge Alsup.

Draft/Edit Declaration OfAdam Gutride In Support Of 1First Motion To Amend/Correct Second AmendedComplaint

75 S

Date Timekeeper


Prepare For, Attend Motion Hearing Re Motion To 01/04/07 4.5Amend/Correct Second Amended Complaint (includestravel time from NYC to SF for MRR)

Review Request For Further Briefing. 01/09/07 .25

Review Defendants' Response To Request For Further 01/16/07 .5Briefing

Draft, Edit Response To Order Requesting Further 01/16/07 7.5Briefing (Full And Redacted Versions), Declaration OfAdam Gutride In Support (Full And RedactedVersions), Motion To Seal

Review Request For Further Briefing 0 1/17/07 .25

Review Order Granting Motion To File Documents 0 1/17/07Under Seal

Review Declaration Of Bruce A. Ericson In Support 0 1/22/07Of Defendants' Response To January 17, 2007 RequestFor Further Briefing

Review Declaration Of Patricia J. Medina In Support 0 1/22/07Of Defendants' Response To January 17, 2007 RequestFor Further Briefing

28.5

.25 .25

.5 .5

11.5 .5 .5 19.5

Date Timekeeper


Review Response Of Joint Defendants To January 17, 01/22/07 .5 .5 .52007 Request For Further Briefing

Draft, Edit Brief Re Order For Further Briefing Filed 01/22/07 14 36 25By (Full And Redacted Versions), Declaration OfSeth Safier In Support (Full And Redacted Versions),Motion To Seal, Proposed Order

Draft, Edit Letter Re Discovery Dispute 01/23/07 2.5 .25

Review Order Continuing Hearing On Discovery 01/23/07 .25 .25Dispute.

Review Letter From Patricia J. Medina To Honorable 01/23/07 .25 .25William H. Alsup Re Discovery Dispute

Review Order By Judge Alsup Granting Motion To 01/23/07 .25Seal

Review Third Request For Further Briefing. 01/25/07 .25 .25 .25

Draft, Edit Stipulation Re Order Stipulation Re: Class 01/29/07 .5 .25Certification Schedule;

Review Order Re Class Certification Schedule 01/30/07 .25 I .25

Review Declaration Of Gilbert R. Serota In Support Of 01/30/07 .25 .25 .5Defendants' Response To January 25, 2007 RequestFor Further Briefing

3.5

Date Timekeeper


Review Defendants' Response To Court's Third 01/30/07 .25 .25 .25Request For Further Briefing.

Draft, Edit Response To Third Request For Further 01/30/07 5.5 7.5 18Briefing

Review Erratum Re: Defendants' Response To Court's 02/02/07 .25 .25Third Request For Further Briefing

Review Order Continuing Discovery Dispute Hearing 02/09/07 .25

Review Fourth Request For Supplemental Briefing. 02/15/07 .25 .25 .25

Review, Edit Stipulation And [Proposed] Order Re 02/15/07 .5 .25Extension Of Time To Respond To Fourth Request ForFurther Briefing

Review Order Granting In Part Stipulated Request For 02/16/07 .25Extension Of Time

Draft, Edit Response To Fourth Request For 02/21/07 8.5 13 5.5Supplemental Briefing

Review Defendants' Response To Court's Fourth 02/21/07 1 1 .5Request For Further Briefing

Review Order To Clarify Submission. 02/22/07 .25 .25 .25

Review Notice Of Impending Order To Show Cause. 02/22/07 .25 .25 .25

Date

Pleadings, Hearings Filed orComp-leted AJG

Draft, Edit Response To Order To Clarify Submission 02/22/07 4

Review Defendants' Response To Court's Fourth 02/23/07 .5Request For Further Briefing

Draft, Edit Response To Re Fourth Request For 02/23/07 6.5Further Briefing, Questions 5-6

Review Order Granting Plaintiffs' Motion To Compel 02/26/07 .25Discovery And Vacating Hearing.

Review Order To Show Cause Why Tentative Order 02/26/07 1Should Not Be Made Final.

Review Fund Defendants' Response To Tentative 03/05/07 .5Ruling

Draft, Edit Response To Order To Show Cause 03/05/07 18

Review Order Re Reply Briefs 03/05/07 .25

Review Request Signed By Judge William Alsup 03/06/07 .25

Draft/Edit Reply Memorandum To Order to Show 03/07/07 9.5Cause Why Tentative Order Should Not Be Adopted

Review Defendants' Reply To Plaintiffs Response To 03/07/07 .5Order To Show Cause Why Tentative Order ShouldNot Be Made Final

Timekeeper

MRR SAS KER KJS JPM EJM

7 1

.5 .5

4.5 10.5

25

1 1

.5 .75

8.5 8.75

.25

.25

24 5

.5 .5

Date Timekeeper


Review Order Identifying Claims To Proceed And 03/09/07 .5 . 5 . 5Dismissing All Other Claims And Granting Motion ToAmend In Part

Review Notice Re Class Certification Issues . 03/12/07 .25 .25 .25

Review Transcript Of Proceedings Held On 01/04/07 03/15/07 .25

Draft, Edit, Confer With Clients Re Third Amended 03/21/07 36 35 4.25Complaint (Redacted And Full Versions), Motion ToSeal

Review Order Granting Motion To Seal 03/22/07 .25

Draft Mediation Statement 03/25/07 4.5 15.75

Review Motion To Dismiss Count IV Of Plaintiffs' 03/28/07 1 1.25 1Third Amended Complaint

Draft, Edit Letter From Adam Gutride To Compel 04/02/07 3.5 .25 .25Interrogatory Answers By Wells Fargo Investments(Redacted And Full Versions), Motion To Seal

Review Order Granting Plaintiffs Motion To Seal 04/02/07 .25

Review Order Setting Hearing Re Plaintiffs Discovery 04/03/07 .25Dispute

Review Defendants' Letter Re Discovery Dispute 04/04/07 .25

Date Timekeeper


Draft, Edit Memorandum In Opposition Re Motion To 04/04/07 8 . 5Dismiss Count Iv Of Plaintiffs' Third AmendedComplaint (Redacted And Full Versions), Motion ToSeal

Review Order Granting Motion To Seal 04/05/07

Prepare For, Attend Discovery Hearing 04/05/07

Review Request For Proposed Form Of Order. 04/06/07

Review Reply Memorandum Re Motion To Dismiss 04/06/07Count IV Of Plaintiffs' Third Amended Complaint

Draft Proposed Order Re Letter Granting Plaintiffs 04/06/07Motion To Compel Responses To Interrogatories ByWells Fargo Investments

Review Order Granting Plaintiffs Motion To Compel 04/09/07Responses To Interrogatories By Wells FargoInvestments.

Review Request For Information. Signed By Judge 04/10/07Alsup

Review Response Of Defendants Wells Fargo & 04/11/07Company And Wells Fargo Investments, To TheCourt's Request For Information

1 11 11 5

Date Timekeeper


RPvipw RPennneP Tn ThP Cnrnrt'Q RPniiPQt Fnr (14/1 1/(17 95

Information By Wells Fargo Fund Management, ,Wells Fargo Funds Trust.

Review Answers Of Defendants To Plaintiffs' Third CAmended Consolidated

Review Motion For Judgment On The Pleadings Filed CBy Funds Defendants, Wells Fargo Investments,Declaration Of Amy Marth, Request For JudicialNotice, Proposed Order

Review Order Denying Motion To Dismiss Third CAmended Complaint

Prepare For, Attend, Draft Statement Re Settlement CConference

Draft, Edit Notice By Ronald Siemers Of Change Of CLaw Firm Name

Review Notice And Order Setting Further Settlement CConference

Draft, Edit Motion To Certify Class Filed By Ronald CSiemers (Full And Redacted Versions); Declaration OfSeth Safier (Full And Redacted Versions), Motion ToSeal

1) S 1) S

Pleadings, Hearings

Review Order Granting Motion To Seal

Draft, Edit, Confer With Client Re Memorandum InOpposition To Motion For Judgment On ThePleadings; Declaration Of Adam Gutride

Review Memorandum In Opposition To Plaintiffs'Motion For Class Certification Filed By FundsDefendants, Declaration Of Jason Skaggs, AndrewOwen

Review Reply Memorandum In Support OfDefendants' Motion For Judgment On The Pleadings

Review Broker-Dealer Defendants' Memorandum InOpposition To Plaintiffs' Motion For ClassCertification, Declarations Of Jonathan Blake, BruceEricson

Draft/Edit Replies To Memorandum In Opposition ToPlaintiffs' Motion For Class Certification (Full AndRedacted Versions), Declaration Of Adam Gutride(Full And Redacted Versions), Motion To Seal

Review Order Granting Motion To Seal

Review Request For Briefing.


04/23/07

04/26/07 28.25

05/03/07 .75

05/03/07 .5

05/03/07 .75

05/10/07 21.5

05/14/07 .25

05/15/07 .25

1) 5

Date

Pleadings, Hearings Filed orComp-leted AJG

Draft/Edit Errata Re Reply To Opposition Re Class 05/15/07 .25Certification

Review Notice Of Hearing And Request For 05/16/07 .25Information Re Forrest McKenna.

Review Further Notice Re McKenna. 05/16/07 .25

Prepare For, Attend Motion Hearing Re Motion For 05/17/07 6.5Judgment On The Pleadings

Review Order Granting Defendants' Motion For 05/17/07 .25Judgment On The Pleadings

Review Response In Support Of Request For 05/21/07 .75Information Re Forrest McKenna Filed By FundsDefendants.

Review Response To Request For Briefing Re Ronald 05/21/07 .5Siemers And Loss Causation By Funds Defendants.

Draft/Edit, Confer With Client Re Response In 05/21/07 14.5Support Of Class Certification To Request For FurtherBriefing.

Draft/Edit, Confer With Client Re Response To 05/21/07 10.5Request For Further Briefing Re Forrest McKenna,Declaration Of Adam Gutride

Timekeeper

MIRR SAS KER KJS JPM EJM

1

.25 .25

.25

3

.25

.25 .5

.5 .5

23.5 18.5

1.5 .75

Date Timekeeper


Prepare For, Attend Hearing Re Forrest McKenna 05/23/07 4.5 1 5

Review Order Denying Certification Of Forrest 05/23/07 .25 .25 .25McKenna As A Class Representative.

Prepare For, Attend Hearing Re Motion To Certify 05/24/07 14.75 16.5 10Class

Draft/Edit Declaration Of Ronald Siemers Amending 05/25/07 7.5 .5Lead Plaintiffs Certification

Review Request For Information 05/30/07 .25 .25 .25

Review Response To Request For Information Re Fees 05/31/07 .25 .25 .25By Funds Defendants.

Draft/Edit Response To Order Requesting Further 05/31/07 6.5 .5 2.5Information.

Review Transcript Of Proceedings Held On 04/05/07 05/31/07 .25Before Judge William Alsup.

Review Order Granting Class Certification And 06/01/07 .5 .5 .5Confirming Class Representative And Class Counsel

Negotiate, Edit Stipulation And [Proposed] Order 06/04/07 .5 .25Regarding Extension Of Time For Submission OfProposed Form Of Class Notice ^ ^ ^

Date Timekeeper


Review Order Regarding Extension Of Time For 06/05/07 .25 .25Submission Of Proposed Form Of Class Notice.

Prepare For, Attend Settlement Conference, Draft 06/14/07 24 20 12Settlement Conference Statement and DamagesAnalysis

Negotiate, Edit Stipulation And [Proposed] Order 06/14/07 .5 .25Regarding Extension Of Time For Submission OfProposed Form Of Class Notice

Review Order Denying Stipulated Request For 06/15/07 .25 .25Extension Of Time

Draft, Edit Response To Order Re Form, Method And 06/15/07 1 .5Content Of Class Notice

Review Notice And Order Setting Further Settlement 06/18/07 .25Conference

Review Order Re Proposed Class Notice. 06//07 .25 I .25

Draft, Negotiate, Edit Joint Response To Order Re 06/25/07 1.5 .5Class Notice With Revised Proposed Class Notice)

Draft, Edit Errata Re Corrected Proposed Class Notice 06/26/07 .25 .5

Review Order Re Proposed Notice And Method Of 06/27/07 .25 .25Notice.

Pleadings, Hearings

Prepare For, Attend Settlement Conference

Negotiate, Draft, Edit, Confer With Client Re:Stipulation Of Settlement By Funds Defendants.(Attachments: # 1 Exhibit 1 - [Proposed] PrelimOrder# 2 Exhibit 2 - Not Of Sett (Short)# 3 Exhibit 3 -Not Of Sett (Long)# 4 Exhibit 4 - [Prop] Plan# 5Exhibit A To Exhibit 4# 6 Exhibit 5 - [Prop] FinalOrder# 7 Exhibit 6 - Prospectus Lang# 8 Exhibit 7 -Sai Discl)

Review Notice Of Hearing On Request ForPreliminary Approval

Draft/Edit Response To Order Requesting ExpertReport In Connection With Preliminary Approval OfSettlement

Prepare For, Attend Motion Hearing Re PreliminaryApproval

Draft/Edit Lead Plaintiff s Supplemental SubmissionRe Preliminary Approval Of Settlement (Full AndRedacted Versions), Declaration Of Adam Gutride InSupport (Full And Redacted Versions), Motion ToSeal, Errata Re Same


0'

0'

0'

0'

0'

06/28/07 6. 5 6

Pleadings, Hearings

DateFiled orComp-leted

Review Order Granting Motion To Seal 07/30/07

Review Letter From Gilbert R. Serota Re United States 07/31/07Court Of Appeals Opinion)

Review Order Re Amended Forms 08/01/07

Draft, Edit, Negotiate Joint Submission Re Class OFNotice In Response To August 1, 2007 Order

Review Order Preliminarily Approving Settlement. OF

Draft, Negotiate Edit Joint Submission Regarding OFProposed Settlement Schedule And Revised DisclosureLanguage In Response To The Court's August 3, 2007Order

Draft, Edit Notice Of Voluntary Dismissal Without OFPrejudice By Plaintiff Forrest McKenna

Review Order Preliminarily Approving Settlement, OFNotice, And Setting Fairness Hearing.

Review Transcript Of Proceedings Held On 05/24/07 OFBefore Judge William Alsup

Review Transcript Of Proceedings Held On 07/11/07 OFBefore Judge William Alsup.

Timekeeper

AJG MIRR SAS KER KJS JPM EJM

1) 5

Date Timekeeper

Pleadings, Hearings Filed orComp-leted AJG MIRR SAS KER KJS JPM EJM

Draft, Edit Motion for Attorneys ' Fees and Expenses 12/21/07 7.5 6.25

Draft, Edit Declaration of Adam Gutride In Support Of 12/21/07 11.5 1.5 1.75 .25 .25 .25 .25Motion for Attorneys' Fees and Expenses

Draft, Edit Declaration of Ronald Siemers In Support 12/21/07 2.5 .5of Motion for Attorneys' Fees and Expenses

TOTAL 491.75 559.25 323.25 1 0.5 12 55.5

EXHIBIT C

Discovery

Draft initial disclosures, confer with client re same,review Defendants' initial disclosures

Draft, review answers to, meet and confer regarding:First set of interrogatories to all Defendants

Draft, review answers to, meet and confer regarding:Second Set of interrogatories to Funds Defendants

Draft, review answers to, meet and confer regarding:Second Set of interrogatories to Wells FargoInvestments

Draft, review answers to, meet and confer regarding:Second Set of interrogatories to Wells Fargo & Co.

Draft, review answers to, meet and confer regarding:Second Set of interrogatories to H.D. Vest Investments

Draft, review answers to, meet and confer regarding:Third set of interrogatories to funds defendants

Review answers to, meet and confer regarding first setof requests for production to Defendants

Draft, review answers to, meet and confer regarding:Second set of requests for production to Defendants

Draft, review answers to, meet and confer regarding:

Timekeeper

AJG MRR SAS KER KJS JPM EJM

.75 7 .25

16.5 1.5 3.5

8.5 4.5 1.5

4.5 2 .75

.75 .25

5.5 1

17.5 1.25 1

12.5 2 1.5

13.5 1.25

1.5 6.5

Discovery

Third set of requests for production to Defendants

Draft, review answers to, meet and confer regarding:subpoenas to third party shelf-space fund issuers;review documents produced

Draft, review answers to, meet and confer regarding:subpoenas to third party broker-dealers for WellsFargo funds; review documents produced

Draft, review answers to, meet and confer regarding:subpoena to Wells Fargo Investments

Review, communicate with clients re, draft answers to, 2meet/confer with defendants re answers to first set ofrequests for admission to Forest McKenna

Review, communicate with clients re, draft answers to,meet/confer with defendants re answers to first set ofrequests for admission to Ronald Siemers

Review, communicate with clients re, draft answers to, 2meet/confer with defendants re answers to first set ofrequests for production to Forest McKenna; reviewand produce documents

Review, communicate with clients re, draft answers to,meet/confer with defendants re answers to first set ofinterrogatories to Forest McKenna

Timekeeper


Discovery

Review, communicate with clients re, draft answers to,meet/confer with defendants re answers to first set ofinterrogatories to Ronald Siemers

Review, communicate with clients re, draft answers to,meet/confer with defendants re answers to second setof interrogatories to Ronald Siemers

Review and produce additional documents on behalf ofRonald Siemers

Review documents: Guinn Eiland (HD Vest)

Review documents: Joyce Kulasxa (HD Vest)

Review documents: Alan Robbins (HD Vest)

Review documents produced by Wells FargoInvestments ( 183,000 pages)

Review documents produced by HD Vest Investments(6100 pages)

Review documents produced by Wells Fargo FundsManagement (30,000 hard copy pages, 36,000electronic pages, plus databases/spreadsheets)

AJG MRR

3.5

2.5

1

3.5

1.5

1.25

3.5 18

1. 25

25 .25

Review documents produced by Wells Capital .2Management (30 pages)

L

1

1

1

50 84.5 2 82.25 153

Timekeeper

SAS KER KJS JPM EJM

25

Discovery

Review documents produced by Stephens, Inc. (1500pages)

Timekeeper


2.5

Review documents produced by Wells Fargo Funds 5.Trust (23,000 pages)

Prepare for, attend deposition of Ronald Siemers(includes travel time)

Prepare for, attend deposition of Forrest McKenna 1 i(includes travel time)

Prepare for, attend deposition of Courtney Unser(includes travel time)

Prepare for, attend deposition of Karla Rabush WFFM 1(30(b)(6) deposition (includes Y2 of travel time fromNYC to SF for MRR, as MRR scheduled deposition atsame time as hearing on another matter in SF)

Prepare for, attend deposition of Sean Faeth WFI 30b6 7deposition (includes travel time for MRR)

Prepare for, attend deposition of Sean Havlin 1 C(deposition scheduled the same week as lead plaintiffSiemers to reduce travel costs to class)

Prepare for, attend deposition of Richard Blank 7.Stephens 30b6 deposition

TimekeeperDiscovery


Prepare for, attend deposition of Lincoln Yersin WFI 12.5 730b6 deposition

Prepare for, attend deposition of Cara Peck (includes 38.5travel time)

Prepare for, attend deposition of Mike Hogan 11.5

Negotiate re, review declaration of Bruce Hyatt in lieu 3.5of deposition

Draft, edit subjects for expert discovery 2.5 .25 1

Review Defendants' subjects for expert discovery .25 .25

Draft deposition notices (including 30b6 topics); 2.5 3.25 3correspondence re deposition scheduling

TOTAL 214.25 286.5 161 84.5 15.25 101.75 153

EXHIBIT D

TimekeeperSettlement, Other

AJG MIRK SAS

Select claims administrator 2.5 1.5

Implement, monitor, follow up re settlement notice; 3.5 3.25meet confer re same

Specifications for claim form, settlement website and 18.5automated phone system, review and test same

Answer class member & media inquiries re settlement 2.5 1

Supervise, answer questions from, claim administrator; 12.5review weekly reports

Press release re first motion to dismiss 2.5 .5 .5

Press release, advertisements re motion to dismiss HD 2 .5 .5Vest

Press release re second motion to dismiss 3.5 .5 .5

Press release re tentative ruling on leave to amend 2.5 .5 .5

Engagement letters, termination letters 3.75 1.25

Research experts, meetings w/ potential experts 2.5 4.5

TOTAL 56.25 6.5 9

EXHIBIT E

Expenses AmountPrinting, Copying and Reproduction $6,530.09De osition/Transcri ts/Notice $19,600.98Fax/Phone $182.16Filing/Witness Fees $933.50Parking $379.00Postage/Delivery $681.90Process Serving $2,342.26Research $175.84Supplies $135.41Travel/Meals/Transportation $20,585.26Contract Paralegals/3IParty Legal $2,532.50

Total $54,078.90