Declaration of Stephen R. Neuwirth, Esquire - In re Processed Egg ...

UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
IN RE: PROCESSED EGG PRODUCTS
ANTITRUST LITIGATION
This document relates to:
MDL Docket No. 2002
08-md-02002
ALL DIRECT PURCHASER ACTIONS
DECLARATION OF STEPHEN R. NEUWIRTH, ESQUIRE
I, Stephen R. Neuwirth, declare as follows:
1. I am a member of the law firm of Quinn Emanuel Urquhart & Sullivan, LLP. I
make this Declaration based on my personal knowledge. If called as a witness, I could and
would competently testify to the matters stated herein.
2. This Declaration pertains to the hours worked by professionals in my firm, and
the expenses incurred by this firm, during the period from January 2009 through February 2011.
My firm has submitted to Interim Co-Lead Counsel in this case (i) monthly reports setting forth
the hours this firm (by individual) has devoted to work on this case for the foregoing period of
time, and (ii) monthly reports setting forth the expenses incurred in connection with this firm’s
work on the case during that same period. These monthly reports are based upon records of time
and expenses regularly maintained by my firm in the normal course of conducting its business.
3. Attached as Exhibit 1 hereto is a chart setting forth, for the January 2009 through
February 2011 time period: (i) the individuals from this firm who have worked on this case; (ii)
the dates of admission (attorneys) or years of experience (non-attorneys) for each individual that
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has worked on this case; (iii) the billable rates charged by each such individual, by year, for work
performed on this case; (iv) the total number of hours that each individual has worked on this
case, by year; (v) the total hours and total lodestar for the firm; and (vi) the total expenses less
assessments for the firm.
4. Attached as Exhibit 2 hereto are the monthly lodestar reports which this firm has
submitted to Interim Co-Lead Counsel for the Direct Purchaser Class Plaintiffs from January
2009 through February 2011. The lodestar amount reflected in the reports attached hereto is for
work assigned by Interim Co-Lead Class Counsel and was performed by professional staff at my
law firm for the benefit of the Direct Purchaser Plaintiff Class. I have reviewed the lodestar
reports attached hereto and can confirm that they are true and correct. All work reported by
individuals (attorneys and non-attorneys) on behalf of the Direct Purchaser Plaintiff Class in this
matter was performed on a wholly contingent basis. Attached as Exhibit 2 hereto are the
monthly lodestar reports which this firm has submitted to Interim Co-Lead Counsel for the
Direct Purchaser Class Plaintiffs from January 2009 through February 2011. The lodestar
amount reflected in the reports attached hereto is for work assigned by Interim Co-Lead Class
Counsel and was performed by professional staff at my law firm for the benefit of the Direct
Purchaser Plaintiff Class. I have reviewed the lodestar reports attached hereto and can confirm
that they are true and correct. All work reported by individuals (attorneys and non-attorneys) on
behalf of the Direct Purchaser Plaintiff Class in this matter was performed on a wholly
contingent basis. The rates set forth in the monthly reports attached as Exhibit 2 are the usual
and customary, historical hourly rates in effect at the time work was performed. These billing
rates applied are the standard rates our firm applied during this period.
5. Attached as Exhibit 3 hereto are monthly charts setting forth the expenses
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incurred by this firm in connection with this litigation from January 2009 through February
2011. These costs were incurred on behalf of the Direct Purchaser Plaintiff Class by my firm on
a contingent basis, and have not been reimbursed.
I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct.
Executed on September 7, 2012 at New York, New York.
/s/ Stephen R. Neuwirth
Stephen R. Neuwirth
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EXHIBIT 1

Quinn Emanuel Urquhart & Sullivan, LLP
Neuwirth, Stephen - Partner
ADMITTED TO PRACTICE: 1988
Rate Hours Rate x Hours
2008 $950.00 144.60 $137,370.00
2009 $950.00 210.80 $200,260.00
2010 $950.00 106.60 $101,270.00
2011 $950.00 7.00 $6,650.00
Cumulative Hours 469.00
Cumulative Lodestar $445,550.00
Rashid, Sami - Associate
ADMITTED TO PRACTICE: 2006
Rate Hours Rate x Hours
2008 $400.00 10.00 $4,000.00
2009 $400.00 0.00 $0.00
2010 $400.00 0.00 $0.00
2011 $400.00 0.00 $0.00
Cumulative Hours 10.00
Cumulative Lodestar $4,000.00
Turner-Dodge, Lee - Law Clerk; Associate
ADMITTED TO PRACTICE: 2009
Rate Hours Rate x Hours
2008* $295.00 129.60 $39,222.00
2009 $370.00 22.40 $8,288.00
2010 $370.00 0.00 $0.00
2011 $370.00 0.00 $0.00
Cumulative Hours 152.00

Cumulative Lodestar $47,510.00
*Rate was 295 for 116.4 hours and 370 for 13.2 hours.
Glunt, Robert - Law Clerk; Associate
ADMITTED TO PRACTICE: 2009
Rate Hours Rate x Hours
2008* $295.00 68.10 $20,374.50
2009** $370.00 136.60 $50,648.00
2010*** $380.00 257.70 $98,746.00
2011 $390.00 0.00 $0.00
Cumulative Hours 462.40
Cumulative Lodestar $169,768.50
*rate 295 for 64.3 hours; 370 for 3.8 h
**rate was 370 for 126 hour and 380 for 10.6 h
Martinez, Christine - Paralegal
Rate Hours Rate x Hours
2008 $250.00 2.30 $575.00
2009 $250.00 0.00 $0.00
2010 $250.00 $0.00
2011 $250.00 $0.00
Cumulative Hours 2.30
Cumulative Lodestar $575.00
Edison, Harold - Lit. Support
Rate Hours Rate x Hours
2008 $250.00 0.50 $125.00
2009 $0.00 $0.00
2010 $0.00 $0.00
2011 $0.00 $0.00
Cumulative Hours 0.50

Cumulative Lodestar $125.00
McNamara, Chris - Law Clerk; Associate
ADMITTED TO PRACTICE: 2011
Rate Hours Rate x Hours
2008 $0.00
2009 $295.00 31.30 $9,233.50
2010 $295.00 0.00 $0.00
2011 $0.00 0.00 $0.00
Cumulative Hours 31.30
Cumulative Lodestar $9,233.50
Bandes, James - Lit. Support
Rate Hours Rate x Hours
2008 $250.00 2.00 $500.00
2009 $0.00 0.00 $0.00
2010 $0.00 0.00 $0.00
2011 $0.00 0.00 $0.00
Cumulative Hours 2.00
Cumulative Lodestar $500.00
Bernstein, Cheryl - Lit. Support
Rate Hours Rate x Hours
2008 $150.00 3.70 $555.00
2009 $0.00 $0.00
2010 $0.00 $0.00
2011 $0.00 $0.00
Cumulative Hours 3.70

Cumulative Lodestar $555.00
Rocke, Shane - Lit. Support
Rate Hours Rate x Hours
2008 $150.00 3.50 $525.00
2009 $0.00 $0.00
2010 $0.00 $0.00
2011 $0.00 $0.00
Cumulative Hours 3.50
Cumulative Lodestar $525.00
Lee, Michael - Lit. Support
Rate Hours Rate x Hours
2008 $150.00 1.10 $165.00
2009 $0.00 $0.00
2010 $0.00 $0.00
2011 $0.00 $0.00
Cumulative Hours 1.10
Cumulative Lodestar $165.00
Aslam, Jehan - Associate
ADMITTED TO PRACTICE: 2007
Rate Hours Rate x Hours
2008 $0.00
2009 $390.00 75.10 $29,289.00
2010 $0.00 0.00 $0.00
2011 $0.00 0.00 $0.00
Cumulative Hours 75.10

Cumulative Lodestar $29,289.00
Nelson, Roy - Man. Clerk
Rate Hours Rate x Hours
2008 $0.00
2009 $0.00 $0.00
2010 $280.00 0.30 $84.00
2011 $0.00 $0.00
Cumulative Hours 0.30
Cumulative Lodestar $84.00
Liao, Joe - Lit. Support
Rate Hours Rate x Hours
2008 $0.00
2009 $0.00 $0.00
2010 $150.00 3.70 $555.00
2011 $0.00 $0.00
Cumulative Hours 3.70
Cumulative Lodestar $555.00
Harrington, Ben - Associate
ADMITTED TO PRACTICE: 2010
Rate Hours Rate x Hours
2008 $0.00
2009 $390.00 8.90 $3,471.00
2010 $0.00 0.00 $0.00
2011 $0.00 0.00 $0.00
Cumulative Hours 8.90

Cumulative Lodestar $3,471.00
Laaraj, Amy - Paralegal
Rate Hours Rate x Hours
2008 $0.00
2009 $0.00 $0.00
2010 $0.00 $0.00
2011 $250.00 28.50 $7,125.00
Cumulative Hours 28.50
Cumulative Lodestar $7,125.00
Friedland, Amos -- Associate
ADMITTED TO PRACTICE: 2010
Rate Hours Rate x Hours
2008 $0.00
2009 $0.00 $0.00
2010 $0.00 $0.00
2011 $390.00 54.90 $21,411.00
Cumulative Hours 54.90
Cumulative Lodestar $21,411.00
CUMULATIVE FIRM HOURS 1309.20
CUMULATIVE FIRM LODESTAR $740,442.00
EXPENSES LESS ASSESSMENTS $78,952.58

ate 370 Dec 13.20 hrs $4,884

*** rate was 380 for 164 hr and 390 for 93.4 hrs

EXHIBIT 2

EXHIBIT 3