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Margo Piscevich, NV Bar No. 0917
Mark J. Lenz, Esq., NV Bar No. 4672
Piscevich & Fenner
499 West Plumb Lane, Suite 201
Reno, Nevada 89509
Tel: (775) 329-0958
Fax: (775) 329-2666
Attorneys for DEFENDANTS



U.S. DISTRICT COURT
DISTRICT OF NEVADA



KEVIN J . MIRCH, ESQ.,

Plaintiff,

v.

BRUCE BEESLEY, ROB BARE, BRIDGET ROBB
PECK, DONALD CHRISTENSEN, STATE BAR OF
NEVADA, DOES I-X, A-Z CORPORATIONS,


Defendants
Case No. 3:05-cv-00641-RLH-RAM
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Suppl ement t o Response t o Or der r e Fees
Defendants Bruce Beesley, Bridget Robb Peck and Donald Christensen, by and through
their counsel of record, Piscevich & Fenner, submit their Supplement to their response to the
Courts Order regarding attorneys fees, dated J anuary 9, 2007, in compliance with LR 54-16
and Kerr v. Screen Extras Guild, 526 F.2d 67 (9
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Cir. 1975), as follows:
1. I t emi zat i on and desc r i pt i on of w or k per f or med:
An itemization and description of the work performed is contained in the Billing
Statements attached hereto as Exhibit A. In short, the work consisted of:
1. Review and analysis of Mirchs 400-paragraph Amended Complaint;
- 1 -
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2. Legal analysis of each of the elements of Mirchs [8] alleged claims for relief and
comparison with his asserted facts;
3. Consultations with clients regarding strategic decisions;
4. Outlining and drafting the Motion to Dismiss on behalf of Beesley, Peck and
Christensen;
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5. Legal analysis of Mirchs requests for extension and supporting documentation,
along with briefing relating to Mirchs Petition for a Writ of Mandamus before the Ninth Circuit
Court of Appeals regarding his requested extensions;
6. Legal analysis of Mirchs Opposition to the Motion(s) to Dismiss, and draft
Reply;
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7. Briefing on Motion for Sanctions, including review of Mirchs Opposition and
drafting the Reply;
8. Briefing and hearing on Mirchs Motion for Stay.
2. I t emi zat i on of c ost s c har ged:
The costs charged are itemized and set forth on the Bill of Costs, attached hereto as
Exhibit B.
3. Summar y of t he Case
A. Nat ur e of t he Case
On November 23, 2005, Plaintiff Kevin Mirch (Mirch) filed a complaint in this Court
for the purpose of forestalling a disciplinary proceeding pending against him before the State
Bar. On March 23, 2006, 120 days later, Mirch filed a First Amended Complaint and served it
on Defendants. Defendants asserted that Mirchs First Amended Complaint was a prime

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Drafting of the Motion to Dismiss for Mr Bare and the State Bar was initially commenced by Bar
Counsels office. None of their time is reflected in the Piscevich and Fenner billings.
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example of vexatious and inappropriate litigation, comprising sixty (60) pages and four hundred
(400) paragraphs of repetitive, accusatory, defamatory, largely unintelligible allegations against a
panoply of judges, mediators, attorneys and State Bar officials, all of whom were accused of
conspiring against Mirch to destroy his law practice and reputation. His allegations spanned a
period of twenty (20) years or more, and ranged from nefarious political skullduggery, to
terrorism (bombing of his office), to theft and fraud, to intent to cause Mirch mental harm.
The State Bar complaint against Mirch arose out of a First Amended Complaint he filed
in the Second J udicial District Court, Washoe County, Nevada, styled Kevin J. Mirch, Doe
Plaintiffs A-Z v. McDonald, Carano & Wilson, LLP, Leigh Goddard, Esq., and Doe Attorneys 1-
10., case no. CV02-05644. On October 9, 2003, District J udge J ames Hardesty entered an Order
Dismissing Mirchs lawsuit, imposing sanctions pursuant to NRCP 11, and referring the matter
to the State Bar for disciplinary investigation. .
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Mirchs current First Amended Complaint mirrored the First Amended Complaint that
was the subject of J udge Hardestys Order. His First Amended Complaint appeared to be
nothing more than an attack by Mirch on the underlying discipline complaint. The framework of
his attack comprised five Claims for Relief beginning at Paragraph 260 and continuing through
Paragraph 400. The Five Claims were: (1) Combination and Conspiracy in Violation of Section
1 of the Sherman Act and Section 4 of the Clayton Act; (2) Constitutional Violation [of] Due
Process; (3) Breach of the Covenant of Good Faith and Fair Dealing; (4) Tortuous (sic)
Interference with Business; and (5) Injunctive Relief.
B. Di f f i c ul t y of t he Case
The difficulty of the case was first manifested in the First Amended Complaint itself, and
what may be termed the Mirch Factor. The First Amended Complaint was convoluted,
rambling, unintelligible in large part, and extremely difficult to comprehend. Its 400 paragraphs
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recited a sort of 20-year history of Mirchs perceived conspiracies by various attorneys, judges,
the State Bar and the Nevada Supreme Court. In addition, the purported federal question claims
were difficult to analyze because the alleged factual predicates were spread over 400 paragraphs.
C. The r esul t obt ai ned and t he amount i nvol ved
Defendants were successful in obtaining a dismissal of Mirchs First Amended
Complaint. Given that his demand was in excess of $75 Million, [First Amended Complaint,
283] the result obtained was favorable.
D. Ti me and l abor r equi r ed
The Billing Statements attached as Exhibit A reflect approximately 125 hours of legal
work required from the commencement of the litigation through the order dismissing the First
Amended Complaint. The labor involved was quite intensive, necessitating extensive legal
research into the federal question claims, and extensive factual analysis resulting from the
convoluted nature of Mirchs pleadings. The file itself comprises four separate folders. As
noted in counsels Declaration attached hereto as Exhibit C, the bill was evenly divided
between the State Bar, including Rob Bare, and the other Defendants. The work, however, was
necessary for both sets of Defendants.
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E. Novel t y and di f f i c ul t y of quest i ons i nvol ved
Because of the Mirch Factor, refuting his allegations and arguments was necessarily
novel and difficult. The Motion to Dismiss on behalf of the Individual Defendants comprised 23
pages of legal and factual analysis and argument. The combined federal question and state law
claims needed to be addressed separately. The federal questions required analysis of subject
matter jurisdiction under the Sherman and Clayton Acts, the Younger abstention doctrine and
Eleventh Amendment immunity, along with an analysis of qualified immunity. The State law
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Case 3:05-cv-00641-RLH-RAM Document 56 Filed 03/16/07 Page 4 of 7

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claims required analysis of civil conspiracy claims, bad faith and injunctive relief, all of which
were made doubly difficult by the convoluted nature of the Complaint.
F. Sk i l l r equi si t e t o per f or m l egal ser vi c e pr oper l y
As noted, analysis of the Sherman and Clayton Acts, Younger abstention issues, the
Eleventh Amendment and the pendant state law claims required a good deal of skill. Organizing
the analyses into a coherent, logical presentation was made difficult by the nature of Mirchs
pleadings, but it was accomplished.
G. Pr ec l usi on of ot her empl oyment by at t or ney due t o
ac c ept anc e of c ase
Counsel is not aware of other employment that was precluded by accepting this case.
Counsels workload increased significantly, however, as a result.
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H. Cust omar y Fee
Customary business litigation fees in this community range from $200 per hour to well
over $350 per hour. However, the fee charged in this matter was $160 per hour, well below the
customary fee for similar services. In addition, Defendants seek only half the billed fees,
making an effective rate of $80 per hour.
I . Whet her Fee i s f i x ed or c ont i ngent
Counsels fee was a fixed hourly rate. As noted, the fee was also split, so these
Defendants were paying only half of the billed fees.
J . Ti me l i mi t at i ons i mposed by c l i ent or c i r c umst anc es
No time limitations are applicable here.
K. Ex per i enc e, r eput at i on and abi l i t y of t he at t or neys
Piscevich & Fenner has been a premier insurance defense firm in Northern Nevada for
over 20 years. Margo Piscevich has over 35 years experience in litigation, has served on
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numerous State Bar and ABA committees, as well as being President of the State Bar of Nevada.
Mark J . Lenz has 15 years experience in litigation, and serves on the State Bar CLE Programs
Committee. The reputation and ability of Defendants counsel is undisputedly high-level.
L. Undesi r abi l i t y of t he c ase, i f any
Although the case was difficult, it was not particularly undesirable, except for having to
deal with Mirchs writing style.
M. Nat ur e and l engt h of pr of essi onal r el at i onshi p w i t h t he
c l i ent
No previous attorney-client relationship existed.
N Aw ar ds i n si mi l ar c ases
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Mr. Mirch has had sanctions awarded against him in several prior cases, including the
Second J udicial District Court case noted above.
4. Ot her i nf or mat i on f or t he Cour t
Defendants seek a monetary sanction in the amount of $9,303.75 in fees, and $240.19 in
recoverable costs, as set forth in the Bill of Costs filed J anuary 19, 2007 (Exhibit B.).

Dated this 16
th
day of March, 2007.
PISCEVICH & FENNER


By: /s/__________________________
Mark J . Lenz, Esq.
499 West Plumb Lane, Suite 201
Reno, NV 89509
Attorneys for Defendants


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CERTIFICATE OF SERVICE

Pursuant to FRCP 5(b), I hereby certify that I am an employee of PISCEVICH &
FENNER and that on this date I caused to be served a true and correct copy of the document
described herein by the method indicated below, and addressed to the following:
Document Served: SUPPLEMENT TO RESPONSE TO
ORDER RE: FEES

Person(s) Served:
Kevin J . Mirch
329 Flint Street
Reno, NV 89501
__________ Hand Deliver
____XX____ U.S. Mail
__________ Overnight Mail
__________ Facsimile
[number]
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DATED this 16
th
day of March, 2007.




______________________________
TERESA BORJ ON



- 7 -
Case 3:05-cv-00641-RLH-RAM Document 56 Filed 03/16/07 Page 7 of 7
EXHIBIT A



















EXHIBIT A
Case 3:05-cv-00641-RLH-RAM Document 56-2 Filed 03/16/07 Page 1 of 10
Case 3:05-cv-00641-RLH-RAM Document 56-2 Filed 03/16/07 Page 2 of 10
Piscevich & Fenner
499 West Plumb Lane
Suite 20 1
Reno, Nevada 89509
775-329-0958
TIN: 88-0175670
State Bar of Nevada
600 East Charleston Boul evarld
Las Vegas, Nevada 89 104
Attenti on: Wayne Blevins. Executi ve Direc
RE: Re: State Bar of Nevada ads. Mirch
My File No.: 60-4446
DATE DESCRIPTION
Apr-05-06 Telephone call from Mr. Nezwek re: case.
Tel ephone call with Mr. Beesley re: service.
Review complaint & guidelines.
Send email to Mr. Nezwek re: initi al
impressions & budget.
Fact InvestigationIDeveloprnent - review K.
Mirch Complaint; receive and review draft
Motion to Di smi ss from State a r ~ memo 10
MP re motions [0 dismiss.
Apr-06-06 Pleadings - draft St ip and Order for Extension
of time to respond to Complaint
Pl eadings - review and revise draft Motion to
Di smiss.
Apr-07-06 Draft letter to Mirch & Mi rch re: Stipulation
and Order for Extension of Time.
Apr-lO-06 Faci InvestigationlDevelopment - telephone
conference with B. Peck re case status and
strategy.
Apr-l 1-06 Fact InvestigationlDevelopment - receive and
review draft Motion 10 Di smi ss re Individual
Defendants; commence review and revision of
Molion
Plead ings - receive and review signed
Stipulation and Order re Extension; e-fi le
Stiplation and Order for j udge's signature.
Pleadings - receive and review Order re
Extension; e-mail correspondence to clients re
stipulation and Order for extension.
HOURS
0.20
0.20
1.00
0.1 0
1.50
0.50
2.00
0.40
0.50
1.00
0.50
0.50
Fi le #:
lnv #:
AMOUNT
32.00
32.00
160.00
16. 00
240.00
87.50
320.00
32.00
80.00
160.00
80.00
80.00
Sep 30, 2006
60-4446
10865
LAWYER
MP
MP
MP
MP
ML
ML
ML
YL
ML
ML
ML
ML
Case 3:05-cv-00641-RLH-RAM Document 56-2 Filed 03/16/07 Page 3 of 10
Other WRitten Motions and Submissions - 0.50 80.00 ML
draft Notice of Appearance and e-file Notice.
Apr-12-06 Reveiw letter from Ms. Mirch agreeing to 0.10 16.00 MP
extension.
Disposit ive Motions - legal analysis and 4.50 720.00 ML
complete draft Motian ta Di smiss. review and
revise Motion to Dismiss.
Apr-J3-06 Fact InvestigationlDevelopment - telephone 0.30 48.00 ML
conference with B. La'mit re Mirch case
status.
Fact InvesligationlDevelopmcnt - receive and 1.00 160.00 ML
review State Bar Complaint and 2nd Judicia!
Order for exhibits to Motion to Dismiss
Budgeting- conUllence preparation of tentative 1.00 160.00 ML
litigation budget
Apr- 14-06 Fact InvestigatianIDevelopment - email to E. 0. 10 16.00 ML
Borrowman re affidavit.
Apr-18-06 Dispositive Motions - continued review and 1.00 160.00 ML
revise Motion to Dismi ss.
Apr- 19-06 Di spositive Motions - review and revise 4.00 640.00 ML
dispositive Motions; proof and revise to final
fonn; review and prepare exhibits to motions;
arrange for e-filing and service.
Other WRitten Motions and Submissions- 3.50 560.00 ML
legal analysis and commence draft Motion for
Sanctions.
Apr-20-06 Other WRi11en Motions and Submissions- 3.50 560.00 ML
continued legal analysis and complete draft
Motion for Sanctions.
Apr-22-06 Other WRitten Motions and Submissions - 1.00 160.00 ML
review and revise Draft Malian for Sanctions
Apr-25-06 Other WRitten Motions and Submissions - 0.30 48.00 ML
proof and revise to final form Moti on for
Sanctions; correspondence to K. Mirch re
Motion.
May-07-06 Review letter from Ms. Witty re: extension. 0.10 16.00 MP
Dictate fax to Ms. Witty granting a 30 day & 0.30 48.00 MP
not a 60 day extension.
May-08-06 Telephone call from Mr. Coulter re: Mirch's 0.30 48.00 MP
activities.
Review fax [Tom Mr. Coulter. 0.10 16.00 MP
Other WRitten Motions and Submissions - 2.50 400.00 ML
receive and review Mirch's Motion for
Enlargement ofTirne to Oppose Motions to
Dismiss; legal analysis and commence draft
Opposition.
May-09-06 Fact InvestigationlDevelopment - receive and 0.10 16.00 ML
review correspondence fr0111 L. Hart re
Declaration
Case 3:05-cv-00641-RLH-RAM Document 56-2 Filed 03/16/07 Page 4 of 10
Fact Investigation/ Development - receive and 0.10 16.00 ML
review correspondence from B. Beesley re
Declaration.
Analysis/Strategy - legal analysis re Mirch 1.50 240.00 ML
requests for enlargment of time
Other WRitten Motions and Submissions- 0.60 96.00 ML
review and revi se Opposition to Motion for
Enl argement of Time
Other WRitten Motions and Submissions- 0.50 80.00 ML
draft Declarration for L. Hart re Opposition to
Motion for Enlargement
Other WRitten Motions and Submi ssions - 0.40 64.00 ML
draft Declaration of B. Beesley re Oppositi on
to Motion for Enlargment
Other WRitten Motions and Submissions - 0.40 64.00 ML
draft Declaration of C. Coulter re Opposition
to Motion for Enlargment
Fact investigation/development: courthouse 1.70 136.00 DS
search re prior Mirch cases, prior requests for
enlargement, extensions. in IGT-Siena case;
locate case files at courthouse in Judge
Polaha' s Department; meet with Ms. Ulleheit
re researchi ng case files. copying documents.
May-I 0-06 Other WRitten Mot ions and Submissions - 0.50 80.00 ML
continued legal analys is for Opposition to
Motion fo r Enlargment of Time
Other WRi tten Motions and Submissions - 1.50 240.00 ML
continued legal analysis and review of exhibits
for Opposition to motion to enlarge time
Courthouse research re Mirch, files in IGTv. 6.70 536.00 DS
Siena.
May-I 1-06 Fact Investigat ion/ Development - legal 0.50 80.00 ML
analysis and draft correspondence to K. Mirch
rc request for extension.
Other WRitten Motions and Submissions - 1.00 160.00 ML
conti nued review and preparation of exhibits
for Opposition to Motion for enlargement of
time
Other WRitten Motions and Submissions - 3.50 560.00 ML
continued draft Opposition to Motion for
enl argement of time
May-I 2-06 Pick up copies of documents in Mirch case at 1.30 104.00 DS
Washoe County Courthouse; review
documents and put in chronological order,
separate orders and motions, affidavits.
May- 13-06 Other WRitten Mot ions and Submissions - 3.00 480.00 ML
review and revise draft Opposition to Motion
for Enlargement of Time.
May-I 5-06 Other WRitten Motions and Submissions- 2.50 400.00 ML
proof and revise to final form Opposiiton to
Moti on for Enlargement of Time; review and
prepare exhibi ts for motion; arrange for
e-filing and service.
Case 3:05-cv-00641-RLH-RAM Document 56-2 Filed 03/16/07 Page 5 of 10
May-I 8-06 Analysis/Strategy - telephone conference with 0.50 80.00 ML
Bob Eisenberg re Opposition to Motion to
Enlarge Time; review Motion from L.
Goddard re Mi rch
May-19-06 Fact Inves tigation/ Development - receive and 0.50 80.00 ML
review Order denying Mirch motion for
extension of time; email Order to B. Beesley,
B. Peck, D. Christensen
Other WRirten Motions and Submissions - 2.50 400.00 ML
prepare Motion for Sanctions for e-filing;
review and prepare exhibits for e-filing.
May-24-06 Fact Investigat ion!Deve!opment - receive and 0.50 80.00 ML
review Mirch's Petition for Writ of Mandamus
re Order denying motion for extension.
May-25-06 Other WRitten Motions and Submissions - 4.00 640.00 ML
legal analysis and draft Opposition to Request
for Extension re MOlion for Sanctions.
Other WRitlen Motions and Submissions 0.30 48.00 ML
receive and review Motion for Enlargement of
Time re Opp to Mot ion for Sanctions.
May-26-06 Fact Investigat ionlDevelopment - telephone 0.20 32.00 ML
conference wi th Motion clerk at 9th Cir re
Writ Peti tion and no stipulation.
JUI1-01-06 Other WRitten Motions and Submissions 1.00 160.00 ML
prepare and file Notice of Non-Compliance re
Order to fi le Opposit ions to Motions to
Dismi ss; arrange for service.
JUI1-02-06 Fact Invcsti gationIDcvelopmcnt review Pacer 0.50 80.00 ML
and 9th Circuit information re stay order on
Oppositions.
JUI1-19-06 Fact Investigation/ Development Receive and 0.10 16.00 ML
review Order to respond to wri t petition.
JUI1-20-06 Fact InvestigationIDevelopment - receive and 1.00 160.00 ML
review Order from 9th Cir. re response to Writ
Petition; conference with clients re response;
receive and review transcript of phone
message from K. Mirch to R. Bare re hearing.
JUI1-21-06 Fact Invest igationIDcvelopmcnt. legal 5.50 880.00 ML
analysis for Response 10 Writ Petition;
commence draft Response.
JUI1-23-06 ApcUate Briefs continued legal analysis l'e 7.00 1, 120.00 ML
Bauman factors for granting writ petition;
outline of argument for Response to Petition
for Wril of Mandamus; complete draft
Response to Petition for Writ of Mandamus.
Jun2406 Other WRi tten Motions and Submissions 4.50 720.00 ML
legal analysis and draft Motion to Quash
Subpoena and Declaration in Support.
JUI1-26-06 ApeHate Motions and Submissions Review 2.00 320.00 ML
and revise Response to Petition for Writ of
Mandamus; arrange for filing and service.
JUI1-27-06 Proof and revise to Final Form Marion to 4.00 0.00 ML
Quash Subpoena Duces Tecum ond Not ice of
Case 3:05-cv-00641-RLH-RAM Document 56-2 Filed 03/16/07 Page 6 of 10
Taking Depost ion of Rob Bare; proof and
revise Declarations; prepare exhibits and
arrange for filing and service.
1un-28-06 Court Mandated Conferences - prepare for and 0.80 128.00 ML
attend telephonic conference re Mirch motion
for extension.
Jul-03-06 ApeUate Bri efs - receive and review Mirch' s 0.50 80.00 ML
Reply Briefre writ petition.
Jul-04-06 Fact InvestigalionIDevelopment - receive and 1.00 160.00 ML
review Mirch's Reply in support of petition for
Writ of Mandamus; email to clients re Reply.
Jul-05-06 Telephone conference with D. Clark re Bare 0.50 0.00 ML
deposition; telephone conference with Court re
order on ex parte motion to quash; telephone
conferrence wi th K. Mirch re deposition and
motion to quash.
Jul -1 9-06 Fact Investigat ion/Development - recieve and 0.30 48.00 ML
review correespondence from M. Mirch re
health records
Aug-02-06 Fact Investigat ionlDevelopment - receive and 0.50 80.00 ML
review medical records of K. Mirch.
Aug-05-06 Fact Investigat ion/Development - receive and 0.50 80.00 ML
review Mirch's Opposition to Motoin for
Sanctions.
Aug-09-06 Fact Investigation/Development - receive and 0.20 32.00 ML
review Order re extension of time to Oppose
motion for sanctions.
Aug- 10-06 Other WRitten Motions and Submissions - 4.00 640.00 ML
legal analysis and commence draft Reply in
Support of Motion fo r Sanctions
Aug-12-06 Other WRitten Mot ions and Submissions - 3.00 480.00 ML
cont inued legal analysis and complete draft
Reply in Support of Motion for Sanctions;
email to counsel for review.
Aug-I 7-06 Fact Investigation/Devel opment - email 10 0.20 32.00 ML
clients re Order on Writ Petiti on from 9th
Circuit.
Sep-07-06 Fact Investigation/ Development - receive and 0.50 80.00 ML
review Mirch's Motion for Stay; email to
clients re motion.
Other WRitten Motions and Submissions - 1.00 160.00 ML
legal analysis and draft Opposition to motion
for stay.
Sep- 10-06 Other WRitten Motions and Submissions - 2.00 320.00 ML
continued legal analysis and review and revise
draft Opposi tion to Motion for Stay; emai l to
counsel ror review.
Sep-II-06 Other WRitten Molions and Submissions 1. 00 160.00 ML
proof and revise to final form Opposition to
Motion for Stay; arrange for fi ling and service;
telephone conrerence with Judge McQuaid's
office re hearing on mot ion.
Case 3:05-cv-00641-RLH-RAM Document 56-2 Filed 03/16/07 Page 7 of 10
Sep-12-06 Fact InvestigationIDevelopment - receive and
review Order re heari ng on Motion for Stay;
email to clients re hearing and opposition to
motion.
Sep-19-06 Review fil e & pleadi ngs.
Attend hearing via telephone re: motion to
stay.
Send email to clients re: outcome of hearing.
Total s
FEE SUMMARY:
Lawyer Hours Effecti ve Rate
Margo Piscevich
Mark Lenz
Legal Assistant
Legal Assistant
DISBURSEMENTS
Apr-07-06 Photocopy Expense
Apr- 19-06 Photocopy Expense
Postage Expense
Apr-25-06 Facsimile Expense
Photocopy Expense
Postage Expense
May-08-06 Facsimile Expense
May- l 1-06 Facsimile Expense
Facsimi le Expense
3.20
96.40
9.70
OAO
May-12-06 Washoe County Clerk/copies/Mirch fiI
May-18-06 MPfReimb.Copies
$160.00
$152.61
$80.00
$80.00
May-25-06 Reno Carson Messenger ServicelDelivery
Service
Jun-OJ-06 Photocopy Expense
0.50 80.00
0.30 48.00
0.40 64.00
0.10 16.00
109.70 $16,031.50
Amount
$512.00
$14,711.50
$776.00
$32.00
Disbursements
0. 75
17.00
4.05
0.70
2.75
0.87
l.75
4.20
1.05
57.00
50.00
12.00
0.75
ML
MP
MP
MP
Receipts
Case 3:05-cv-00641-RLH-RAM Document 56-2 Filed 03/16/07 Page 8 of 10
Jun-26-06
Jun-27-06
Jul-08-06
Aug-14-06
Sep- I I-06
Facsimile Expense
Photocopy Expense
Postage Expense
Photocopy Expense
UPS Next Day Air!
Photocopy Expense
Postage Expense
Photocopy Expense
Postage Expense
Totals
Total Fees, Disbursements
Previous Balance
Previous Payments
Balance Due Now
AMOUNT QUOTED:
7.70
36.75
2.22
17. 00
13.62
70-
_._)
0.63
1.50
0.63
$235.17 SO.OO
SI6,266.67
$0.00
$0.00
$16,266.67
so.oo
Case 3:05-cv-00641-RLH-RAM Document 56-2 Filed 03/16/07 Page 9 of 10

Piscevich & Fenner
State Bar of Nevada
600 East Charleston Boulevarld
Las Vegas, Nevada 89104
499 West Plumb Lane
Suite 201
Reno, Nevada 89509
775-329-0958
TIN: 88-0175670
Attention: Wayne Blevins, Executive Di rec
RE: Re: State Bar of Nevada ads. Mirch
My File No.: 60-4446
DATE DESCRlPTION
OCI-1 3-06 Other WRitten Motions and Submissions -
conti nued legal analysis and commence draft
Reply in Support of Motions to Di smiss
OCI-1 8-06 Other WRitten Motions and Submissions-
cont inued legal analysis and draft of Reply in
Support of Motion to Dismiss
Oct-19-06 Other WRitten Motions and Submissions-
conti nued legal analysis and complete draft
Repl y in jSupport of Motions to Di smiss;
Review and revise draft Reply; prepare Tables
of Authorities and Contents; email to counsel
for review.
OCI-23-06 Other WRitten Motions and Submissions-
proof and revise lO final form Reply in Support
of Motions lO Di smiss; arrange for e-fili ng and
service.
Jan-03-07 Review lener from Mr. Bare.
Totals
FEE SUMMARY:
Lawyer Hours Effect ive Rate
Margo Piscevich 0.10 $160.00
File #:
Inv #:
HOURS AMOUNT
3.00 480.00
4.50 720.00
7.50 1,200. 00
1.00 160.00
0. 10 16.00
16.10 $2,576.00
Amount
$ 16. 00
Jan 12,2007
60-4446
Sample
LAWYER
ML
ML
ML
ML
MP
Case 3:05-cv-00641-RLH-RAM Document 56-2 Filed 03/16/07 Page 10 of 10
Mark Lenz 16.00
DISBURSEMENTS
OCl-23-06 Photocopy Expense
Photocopy Expense
Postage Expense
Postage Expense
Totals
Total Fees, Disbursements
Previous Balance
Previous Payments
Bulance Due Now
AMOUNT QUOTED:
$160.00 $2,560.00
Disbursements
- 7 -
) ._)
5.25
1.1 1
1.11
$12.72
Receipts
$0.00
$2,588.72
$16,266.67
$8,133.33
SI0,722.06
SO.OO
EXHIBIT B























EXHIBIT B
Case 3:05-cv-00641-RLH-RAM Document 56-3 Filed 03/16/07 Page 1 of 3
Case 3:05-cv-00641-RLH-RAM Document 56-3 Filed 03/16/07 Page 2 of 3
(Rev.9f89) Bill O(Costs
UNITED STATES DISTRlCT COURT
Kevin J . Mirch, Esq . I
V.
Dislrict of Nevada
BILL OF COSTS
Bruce Beesley I RDb Bare, Bridget Case Number: 3 : 05-cv- 0064l-RIR- RA.1>.1
Ibbb Peck, [bnald Christ ensen, State Bar
o f Nevaaa, DOES I x, A- Z COIp)ratl ons ,
Judgment having been ent ered in the above enti tled action on
1-9-07
against Kevin J . Mir ch, plaint.iff
the Clerk is requested to ta;>; the following as costs:
Fees of the
S
n/a
Fees for service of summons and subpoe na n/a
Fees oflhe court repOrter for all or any part of the transcript necessarily obtained for use in the case
n/a
Fees and disbursements [or printing . ..... ... ..... .
n/a
Fees [or witnesses (i temize on reverse side) ...... .... ................... . .... .
n/a
Fees for e;>;emplification and copies of papers necessarily obtained for use in the case .... $ 196 . 2i
Docket fees under 28 U.S.C. 1923 ............ . n/a
Costs as shown on Mandatc of Co uri o f Appeals
n/a
Compensation of co urt- appointed uperts
n/a
Compensation of interpreters and costs of special interpretation senices under 28 U .S.C. 1828
n/a
Oh ( I
.. )Postage SlO. 62 i .. F . . a.c.s.lJ1tl. . . .1.e ... $ .. 7 .. 7.D .. , .. De ... 1.i.v.ery .....
t er cOStS p ease Itemi ze service $25 __ 62
$ 43.94
TOTAL S
24 0.lQ
SPECIAL NOTE: Att ach to your bi ll an ite mi zation and documentation for reques ted cOSts in all categories.
DECLARA TION
J declare under pena lty of perjury that the foregoi ng costs are conect and were necessarily incurred in th is action and that the services
for which fees have been charged were actually and necessarily performed. A copy of (his bi11lVas mailed today wit h postage
prepaid to: Kevin J. Mirch, Esq . .
S;,,,,",,o'A,,,,"o,,
Name of Atlomey: t-ark J _ Lenz, Esq_
For: Defendants Dale: January 16, 2007
Name ofCl3imi ng PaRY
COSIS are tued in the amoun t of _ _ ______________________ and included in the judgment.
By:
Cltrk of Co un
"D<=,c,C, y'CC"Onc-----------
Date
Case 3:05-cv-00641-RLH-RAM Document 56-3 Filed 03/16/07 Page 3 of 3
WITNESS FEES (Colll IJutatiOIl , d . 28 U.S.C. 182 1 for statutory feu)
A TI"ENDANCE SUBSISTENCE MILEAGE
Total Co.t
NAME AND RESIDENCE Total TOtal Tot,l Each Will1es.s
"'''
Cm'
Do"
CM' Miles Cost
TOTAL
NOTI CE
Sectio n 1924, Title 28, U.S. Code (e rrecti ve Sl' IJt ember I, 1948) IJr ovi des:
'Sec. 1924. Ver ificat ion of bill of costs."
"Before any bill of costs is taxed. the party cla imi ng any item of cost or di sbu rsement shall a1l3ch thereto an amdavit.
made by himself or by hi s duly autborilcd allorney or agcnt having knowledge o f the fac ts, that such item is correct and
bas been necessarily incurred ill the casc and that tbc services for whicb fees bave been cbarged were actually and
necessaril y performed."
Sec a lso Sect ion 1920 ofTitlc 28, which rc'l ds in part 3. 5 follows:
" A bill of costS shall be filed in the case and, upon allowance, included in the judgment or d ccrec."
Th e Fed er a l Rules ofCh' il l'roced ure contain the following pr ovisions:
Rule 54 (d)
"Except when express provi s ioll therefor is made either in a statute o f the United States or in these rules, costs shall
be allowed as of course to the prcvailing party unless Ihe court otherwise directs, hut costs against the Unit ed States, it s
officers, and agencies shall be imposed only to the extent pcrmitted by law. Co sts may be !axcd by the clerk on one day' s
notice. On motion served witbin 5 days thcre:lfter. the :Iction or the cl erk may be reviewed by tbe court ."'
Rule 6(e)
"Whenever 3. party ha s the right or is required to do some act or take some proceedings within a prescribcd period
after the service ofa notice or other paper upon him and the notice or paper is served upon hi m by lIIail. 3 da}"5 shal l be
added 10 the prescribed period."
Rul e 58 ( In Part)
"'Entry o f the judgment s ~ l l !lot be delayed for the mxing OfcoSt8."'
EXHIBIT C























EXHIBIT C
Case 3:05-cv-00641-RLH-RAM Document 56-4 Filed 03/16/07 Page 1 of 4

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Margo Piscevich, NV Bar No. 0917
Mark J. Lenz, Esq., NV Bar No. 4672
Piscevich & Fenner
499 West Plumb Lane, Suite 201
Reno, Nevada 89509
Tel: (775) 329-0958
Fax: (775) 329-2666
Attorneys for DEFENDANTS



U.S. DISTRICT COURT
DISTRICT OF NEVADA



KEVIN J . MIRCH, ESQ.,

Plaintiff,

v.

BRUCE BEESLEY, ROB BARE, BRIDGET ROBB
PECK, DONALD CHRISTENSEN, STATE BAR OF
NEVADA, DOES I-X, A-Z CORPORATIONS,


Defendants
Case No. 3:05-cv-00641-RLH-RAM
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DECLARATION


STATE OF NEVADA )
)ss:
COUNTY OF WASHOE )

I, Mark J . Lenz, declare in accordance with 28 U.S.C. 1746 that the following
statements are true, and that:
1. I am associated with Piscevich & Fenner, counsel of record for Defendants in the
above-referenced action.
2. I make this declaration of my own personal knowledge, and if called upon to
testify as to the matters stated herein, could do so competently.
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Case 3:05-cv-00641-RLH-RAM Document 56-4 Filed 03/16/07 Page 2 of 4

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3. I was the attorney primarily responsible for preparing, reviewing and finalizing
the Motions to Dismiss and subsequent related briefing in this matter. The information in
Defendants Supplement to Response to Order re: Fees filed herewith is, to the best of my
knowledge, complete and accurate.
4. The costs set forth in Defendants Bill of Costs reflect the amounts usually
charged for the items indicated. Piscevich & Fenner does not charge separately for computer
legal research, and no charge is included for it.
5. The firms billings reflect a total of 115.7 hours of attorney time, and 10.1 hours
of legal assistant time expended on this matter through October 23, 2006.
6. The hourly rate for the firm for similar services is $160 for attorney time, and $80
for legal assistant time, which multiplied by the hours expended would total $18,512 for attorney
time and $808 for legal assistant time, or $19,320. However, our billing program makes some
adjustments, resulting in a total bill for fees of $18,607.50.
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7. I have reviewed and edited the billing statements in this case. I know, for
example, that the billing program responds to a task code of 250 with an automatic phrase
Other WRitten Motions and Submissions with an improperly capitalized R in Written. I
had not, at that point, changed the automatic phrase feature to make a correction.
8. Normally, a pair of Motions to Dismiss would not have required as much as 125
hours of work to brief to completion. However, Plaintiff in this case also filed motions for
enlargement of time, a motion for stay, and attempted an interlocutory petition for a Writ of
Mandamus to the Ninth Circuit Court of Appeals, which ultimately proved moot. The hours
spent dealing with the briefing at the Ninth Circuit are included in our billings, as they were
directly related to the Motions to Dismiss.
- 2 -
Case 3:05-cv-00641-RLH-RAM Document 56-4 Filed 03/16/07 Page 3 of 4

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9. The fees and costs charged are reasonable. In this matter, we represented all
Defendants. However, we agreed to represent the State Bar and Mr. Bare on a separate account.
Accordingly, the fees expended on behalf of Beesley, Peck and Christensen are deemed to be
one-half of the amount billed, or $9,303.75.

Dated this 16
th
day of March, 2007.

I declare under penalty of perjury that the foregoing is true and correct.


/s/____________________________
Mark J . Lenz, Esq.


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Case 3:05-cv-00641-RLH-RAM Document 56-4 Filed 03/16/07 Page 4 of 4