Civil Lawsuit Against Madison Cawthorn From The Bopp Law Firm

Case 2:22-cv-00554-JRS-MG Document 9 Filed 12/07/22 Page 1 of 11 PageID #: 119
UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF INDIANA
TERRE HAUTE DIVISION
The Bopp Law Firm, PC, an Indiana professional

corporation,
Plaintiff,
v. Civil Case No. 2:22-cv-00554
Mr. Madison Cawthorn., an individual,
Defendant.
Amended Complaint for Compensatory Damages
Pursuant to this Court’s Order, ECF No. 8, Plaintiff THE BOPP LAW FIRM, PC (“BLF”)
submits this amended complaint against Defendant Mr. Madison Cawthorn as follows:
Introduction
1. This is a civil action for compensatory damages arising under breach of contract and
account stated claims.
Jurisdiction and Venue
2. This action arises under Indiana common law for breach of contract and account stated
claims.
3. This Court has original subject matter jurisdiction under 28 U.S.C. § 1332(a) because the
matter in controversy exceeds $75,000 and is between citizens of different states.
4. BLF is an Indiana professional corporation with its principal place of business in Terre
Haute, Indiana. Therefore, pursuant to 28 U.S.C. § 1332(c)(1), BLF is a citizen of Indiana.
Am. Compl. for

Damages 1
5. Mr. Cawthorn owns a residence at 657 N. Rugby Rd., Hendersonville, North Carolina
28791. According to the Henderson County Auditor website, Mr. Cawthorn is listed as the owner
and property tax bills are sent to this address.
https://lrcpwa.ncptscloud.com/Henderson/PropertySummary.aspx?PARCELPK=101656&pageIn
dex=0.
6. Mr. Cawthorn currently serves as the congressional representative for North Carolina’s
11th Congressional District. The U.S. Constitution requires Members of the House of
Representatives to live in the state they represent. U.S. Const., Art. 1, § 2, Cl. 2.
7. The North Carolina State Board of Elections lists Mr. Cawthorn as an active, registered
voter in Hendersonville, North Carolina. See screenshot of NCSBE Voter Search:
Source: North Carolina State Board of Elections Voter Search, found at:
https://vt.ncsbe.gov/RegLkup/
8. The property tax records, voter registration records, as well as Mr. Cawthorn’s
congressional representation show that he is a citizen of North Carolina. Since BLF is a citizen of
Indiana and Mr. Cawthorn is a citizen of North Carolina, complete diversity exists between the
Am. Compl. for

Damages 2
parties. This Court has original subject matter jurisdiction under 28 U.S.C. § 1332(a) because the
matter in controversy exceeds $75,000 and is between citizens of different states.
9. This Court has the authority to provide for compensatory damages under Indiana common
law and Rule 54 of the Federal Rules of Civil Procedure.
10. This Court has personal jurisdiction over Mr. Cawthorn because he established contacts
within the State sufficient to permit the exercise of personal jurisdiction over them via the
Agreement for Legal Services (“Agreement”) he entered into with BLF.
11. Venue is proper in this district under 28 U.S.C. § 1391(b)(3) because Mr. Cawthorn is
subject to the court’s personal jurisdiction in this District with respect to this action. Further,
venue is proper because this court’s jurisdiction encompasses Vigo County, Indiana, where BLF
is headquartered.
Parties
12. Plaintiff BLF is an Indiana professional corporation headquartered at The National
Building, 1 South Sixth St., Terre Haute, Indiana 47807.
13. Defendant Mr. Cawthorn is an individual residing at 657 N. Rugby Rd., Hendersonville,
NC 28791.
Facts
The Agreement
14. On or about January 10, 2022, BLF began representing Mr. Cawthorn in response to a
challenge to Mr. Cawthorn’s qualifications as a candidate for the U.S. House of Representatives.
(“Challenge Suit”).
15. On or about January 20, 2022, Mr. Cawthorn entered into the Agreement with BLF to
Am. Compl. for

Damages 3
represent him by defending him in the Challenge Suit, including any appeals and relevant
petitions for attorneys’ fees allowed under federal law.
16. The fully executed Agreement is attached to this Complaint as Exhibit 1.
17. James Bopp, Jr. is the sole proprietor of BLF, and at all times material to this matter was
in good standing under the laws of Indiana. Mr. Bopp signed the Agreement on behalf of BLF.
18. Mr. Cawthorn served as a Congressman in the U.S. House of Representatives, is over 18
years of age, and at all times material to this matter was authorized under the laws of both North
Carolina and Indiana to enter into legally enforceable contracts. Mr. Cawthorn signed the
Agreement on his own behalf.
19. In the Agreement, Mr. Cawthorn agreed to pay BLF for its legal services, at agreed upon
hourly rates for BLF attorneys, including James Bopp, Jr., Jeffrey P. Gallant, and Melena Siebert.
Agreement at 1.
20. Mr. Cawthorn agreed to pay the corresponding hourly rates for other BLF attorneys who
may assist in the legal work necessary in defending Mr. Cawthorn in the Defamation Suit. Id.
21. Mr. Cawthorn agreed to pay costs and expenses in addition to the hourly charges for legal
services. Id.
22. Under the terms of the Agreement, all invoices sent to Mr. Cawthorn by BLF were due
and payable within 30 days of receipt by Mr. Cawthorn. Id. at 1.
23. Under the terms of the Agreement, interest accrued at 1.5% per month on past due
accounts until paid. Id.
24. Under the terms of the Agreement, Mr. Cawthorn agreed to pay all attorneys’ fees and
Am. Compl. for

Damages 4
costs BLF incurred for collecting any unpaid amounts owed by Mr. Cawthorn, if legal action by
BLF is necessary to collect any unpaid amounts due. Id.
25. Mr. Cawthorn agreed that any disputes arising under the Agreement would be governed
by Indiana law without giving effect to Indiana’s conflict of law principles and that any court
located in Indiana could resolve the dispute. Id. at 2.
BLF Performance and Mr. Cawthorn’s Breach
26. BLF provided the legal services agreed upon under the Agreement and timely sent
invoices to Mr. Cawthorn on a monthly basis.
27. Beginning on January 10, 2022, when Mr. Cawthorn’s representatives contacted BLF,
BLF performed extensive and time-sensitive work on Mr. Cawthorn’s behalf, researching and
advising him and his campaign on all aspects of a response to the Challenge Suit.
28. This legal work began with advising Mr. Cawthorn of the regulations and rules governing
a legal defense fund—to fund the litigation—and then mounting a substantive response to the
challenge before the North Carolina State Election Board (“Board”).
29. When the Board stayed the challenge to his candidacy, BLF mounted, on Mr. Cawthorn’s
behalf, a challenge in federal court to the North Carolina law under which the challenge to his
qualifications was brought.
30. Along with the litigation in federal court, attorneys at BLF successfully
opposed—twice—the intervention by the challengers, protected his interests in state redistricting
proceedings by opposing the appointment of a special master that was counsel for intervenors,
and advised the campaign in successfully navigating the change in districts.
Am. Compl. for

Damages 5
31. After winning a permanent injunction in the district court, BLF protected Mr. Cawthorn’s
interests by timely filing for attorney’s fees while also fully briefing and arguing the appeal in the
Fourth Circuit by the challengers. As part of a strategic decision in the appellate process, Mr.
Cawthorn agreed to withdraw his pursuit of attorneys’ fees in federal district court, agreeing to
pay those fees under the terms of the Agreement.
32. The Fourth Circuit reversed and remanded the case back to the district court, but Mr.
Cawthorn ultimately lost his primary election shortly after the Fourth Circuit’s decision.
Attorneys at BLF strategically moved to have the district court case dropped as moot, in order to
forego a possibly adverse result that could affect any future campaigns Mr. Cawthorn might
undertake.
33. To date, Mr. Cawthorn has an outstanding, unpaid balance of $193,296.85, apart from
any interest that is due and apart from any fees due for work on collecting overdue amounts, as
provided under the terms of the Agreement. BLF Invoice, September 26, 2022, Ex. 9.
COUNT I:
Breach of Contract Due to Nonpayment for Services Rendered
34. BLF re-alleges and incorporates by reference all previous allegations.
35. Pursuant to the terms of the Agreement, Indiana law governs any dispute related to the
Agreement.
36. Under Indiana law, “[t]o recover for a breach of contract, a plaintiff must prove that: (1) a
contract existed, (2) the defendant breached the contract, and (3) the plaintiff suffered damage as
a result of the defendant's breach.” Collins v. McKinney, 871 N.E.2d 363, 370 (Ind. Ct. App.
Am. Compl. for

Damages 6
2007).
37. “The basic requirements for a contract are offer, acceptance, consideration, and a meeting
of the minds between the contracting parties on all essential elements or terms of the
transaction.” Jernas v. Gumz, 53 N.E.3d 434, 445 (Ind. Ct. App. 2016), trans. denied.
38. Consideration is a “bargained for exchange” whereby the promisor accrues a benefit or
the promisee accepts a detriment. Kelly v. Levandoski, 825 N.E.2d 850, 860 (Ind. Ct. App. 2005).
39. The Agreement is a valid, enforceable contract. BLF offered its legal services to Mr.
Cawthorn in exchange for Mr. Cawthorn’s payment of attorney fees and costs, which Mr.
Cawthorn accepted. Mr. Cawthorn’s promised payment serves as consideration because Mr.
Cawthorn accrued the benefit of legal services in exchange for the detriment of paying BLF’s
fees. The Agreement contained all the essential elements of the terms of this contract. The offer,
acceptance, consideration, and the meeting of the minds between Mr. Cawthorn and BLF are
demonstrated within the Agreement itself, which was signed by Mr. Cawthorn and BLF, who
were authorized under the laws of their respective states to enter into the Agreement.
40. To date, Mr. Cawthorn has not paid $193,296.85 to BLF, apart from any interest that is
due and apart from any fees due for work on collecting overdue amounts, as provided under the
terms of the Agreement.
41. Because Mr. Cawthorn has not paid BLF for the attorney fees, costs, expenses and
interest due, he breached the Agreement.
42. BLF suffered damage totaling $193,296.85, plus the unpaid interest and the fees due for
collecting the unpaid amounts, as a direct result of Mr. Cawthorn’s breach.
Am. Compl. for

Damages 7
COUNT II:
Account Stated Claim
43. BLF re-alleges and incorporates by reference all previous allegations.
44. “The issues tried in an action on an account stated are whether or not the parties settled
their accounts and agreed upon a certain amount due; whether or not there was any agreement,
express or implied, to pay such amount; and, if payment is raised as a defense, whether such
payment was made.” 1 Ind. Law Encyc. Accounts and Accounting § 12.
45. An account stated is an agreement between the parties that all items of an account and
balance are correct, together with a promise, express or implied, to pay the balance. Jackson v.
Trancik, 953 N.E.2d 1087, 1091 (Ind. Ct. App. 2011).
46. An agreement that the balance is correct may be inferred if the debtor fails to object to the
amount owed within a reasonable amount of time. “When the underlying material facts are
undisputed, what constitutes a reasonable time to object to a statement of account is a question of
law.” Auffenberg v. Bd. of Trustees of Columbus Reg'l Hosp., 646 N.E.2d 328, 331 (Ind. Ct. App.
1995).
47. Under Indiana law, if a debtor fails to object to an account until after a lawsuit is filed, the
court will consider this a failure to object within a reasonable time and will support an inference
of the debtor's implied agreement that the account balance is correct. Id.
48. Pursuant to the terms of the Agreement, BLF billed Mr. Cawthorn monthly for attorney
fees and costs through a monthly invoice specifying the services rendered and their cost.
Beginning with the BLF invoice for services rendered in January, 2022, amounts charged to Mr.
Cawthorn went unpaid and are currently unpaid. Invoices, Exs. 2 - 9.
Am. Compl. for

Damages 8
49. Mr. Cawthorn did not object to the amount owed or services rendered on any of the BLF
invoices, Exs. 2 - 9, or to the correctness of the account balance.
50. Therefore, as a matter of law, Mr. Cawthorn has given BLF its implied agreement that the
accounts charged, but unpaid, on the BLF invoices are correct. Since Mr. Cawthorn has failed to
pay this balance and accrued interest, BLF should be awarded damages in the amount of
$193,296.85 on the account stated claim.
Prayer for Relief
WHEREFORE, Plaintiff prays for the relief set forth below:
1. Award compensatory damages to BLF for the unpaid legal fees and costs, in the
amount of $193,296.85 .
2. Award pre-judgment interest on any compensatory damage awarded to BLF against
Mr. Cawthorn.
3. Award all accrued interest on the unpaid balance for attorneys’ fees, costs, and
expenses.
4. Award all attorneys’ fees, costs, and expenses to BLF for prosecuting this action; and
5. Grant any other relief this Court deems appropriate.
Am. Compl. for

Damages 9
Date: December 7, 2022 Respectfully submitted,

/s/ James Bopp, Jr.
James Bopp, Jr. IN No. 2838-84
[email protected]
Lead Counsel for Plaintiff
Melena S. Siebert IN No. 35061-15
[email protected]
Counsel for Plaintiff
THE BOPP LAW FIRM, PC
The National Building
1 South Sixth Street
Terre Haute, IN 47807-3510
(812) 232-2434 - Telephone
(812) 235-3685 - Facsimile
Am. Compl. for

Damages 10
Certificate of Service
I hereby certify that on December 7, 2022, a copy of the foregoing and all attachments
thereto were filed electronically using the Court’s CM/ECF system and will be served via a
service of summons in compliance with Federal Rule of Civil Procedure 4 upon:
Mr. Madison Cawthorn

657 N. Rugby Rd.
Hendersonville, NC 28791
/s/ James Bopp, Jr.

James Bopp, Jr.
Lead Counsel for Plaintiff
Am. Compl. for

Damages 11
Case 2:22-cv-00554-JRS-MG Document 9-1 Filed 12/07/22 Page 1 of 4 PageID #: 130
Exhibit 1
Cawthorn Agreement for Legal
Services - Executed
Exhibit 2
Cawthorn Invoice Feb. 8, 2022
JAMES BOPP, JR.
[email protected]
THE Bopp LAVV Fm1w, PC
ATTORNEYS AT LAW
THE NATIONAL BUTI..DING

TERRE HAUTE, INDIANA 47807-3510
Telephone 812/232-2434 Facsimile 812/235-3685
www.bopplaw.com
INVOICE
February 8, 2022
Madison Cawthorn
Thomas Datwyler
PO Box 183
Hudson, WI 54016
In Reference To:Adm_inistrative Challenge to Candidacy and Suit vs. NCSBE
Professional Services
Hrs/Rate Amount
1/10/2022 MS Phone conference with with Blake Harp 0.20 54.00

regarding NC challenge to candidacy 270.00/hr
1/11/2022 JB Phone conference with Melena Siebert 1.20 756.00

regarding complaint; review complaint 630.00/hr
MS Legal strategy call with client, advisors o.so 243.00

270.00/hr
MS Research, review law on NC challenge statute, 1.40 378.00

possible defenses to same, review challenge 270.00/hr
Madison Cawthorn Page 2
Hrs/Rate Amount
1/12/2022 MS E-mail to client regarding initial research on NC 0.50 135.00

candidacy challenge 270.00/hr
JB Phone conference with Melena Siebert 0.40 252.00

regarding hearing canceled; next steps 630.00/hr
JB E-mail exchange regarding conference call 0.30 189.00

Thursday 630.00/hr
1/13/2022 MS Videoconference with client and James Bopp, 1.30 351.00

Jr. regarding legal strategy on candidacy 270.00/hr
challenge
MS Phone conference with James Bopp, Jr. 0.30 81.00

regarding legal strategy, research needs 270.00/hr
MS Phone conference with Jeffrey P. Gallant 0.10 27.00

regarding research on campaign finance law 270.00/hr
MS Research law regarding candidacy challenge, 1.40 378.00

phone call with James Bopp, Jr. regarding next 270.00/hr
steps; phone call with James Bopp, Jr.
regarding annuity account
JPG Phone call with Melena Siebert regarding 0.20 95.00

research; e-mail regarding research on federal 475.00/hr
legal defense fund; brief check of files
JB Phone conference with client and Melena 1.30 819.00

Siebert regarding complaint 630.00/hr

regarding next steps and legal research 630.00/hr
JB Review prepared retainer agreement; approve 0.30 NO CHARGE

630.00/hr
JB E-mail exchange with local counsel regarding 0.30 189.00

pro hac vice and other matters 630.00/hr
Hrs/Rate Amount
1/13/2022 JB Review email from local counsel; research 1.30 819.00

annunity certification; phone conference with 630.00/hr
Melena Siebert regarding Amnesty Act
1/14/2022 MS Research campaign finance law, House Ethics 4.90 1,323.00

Rules on legal defense fund, email exchanges 270.00/hr
with James Bopp, Jr. and Jeffrey P. Gallant
regarding same
MS Phone conference with Jeffrey P. Gallant 0.50 135.00

regarding campaign finance law, House Ethics 270.00/hr
Rules on legal defense fund

regarding The Amnesty Act 270.00/hr
MS Draft summary document for potential 0.70 189.00

defenses/ offenses 270.00/hr
MS Draft email to client summarizing campaign 0.90 243.00

finance rules, House Ethics Rules 270.00/hr
JPG Phone conferences with Melena Siebert, email 1.70 807.50

with Melena Siebert, James Bopp, Jr. regarding 475.00/hr
questions regarding whether legal defense fund
is regulated as contributions/expenditures and
subject to source and amount limitations;
research federal regulations regarding "in
connections with"
JPG E-mail exchange, check federal 0.60 285.00

officeholder/candidate solicitation rules 475.00/hr
JB Email exchange regarding Defense Fund; 0.50 315.00

review Gabbard Trust 630.00/hr
Hrs/Rate Amount
1/14/2022 JB Review legal research regarding Defense Fund; 0.90 567.00

phone conference with Melena Siebert 630.00/hr
regarding legal request; review email from
Jeffrey P. Gallant
JB Review draft Melena Siebert email regarding 0.60 378.00

Legal Defense Fund; approve; call with Melena 630.00/hr
Siebert regarding Amnesty Act
1/18/2022 MS Review, edit trust agreement, review emails 1.00 270.00

from local counsel, various articles regarding 270.00/hr
defenses to constitutional challenge
JB Revised Legal Defense memo 1.00 630.00

630.00/hr
JB Review email from co-counsel; research on 1.70 1,071.00

legal defense memo; revise legal defense 630.00/hr
memo; send to client
1/19/2022 MS Videoconference with James Bopp, Jr., local 0.80 216.00

counsel, client regarding legal strategy 270.00/hr

regarding potential constitutional claims, 270.00/hr
federal suit
MS Research Younger abstention when state 0.70 189.00

proceeding is stayed; phone conference with 270.00/hr
James Bopp, Jr.

regarding Younger 630.00/hr
JB Review Stay Order; email Melena Siebert 0.30 189.00

630.00/hr

regarding Stay and Younger 630.00/hr
Hrs/Rate Amount

regarding potential constitutional claims, 630.00/hr
federal law suit
JB Phone conference with Catherine and Luke, 0.80 504.00

Melena Siebert and Josh regarding legal 630.00/hr
strategy and federal suit
1/20/2022 JB Phone conference with Josh regarding filing 0.60 378.00

suit; phone conference with Melena Siebert 630.00/hr
regarding next steps
JB Execute retainer and send 0.30 NO CHARGE

630.00/hr

regarding Younger; review email regarding 630.00/hr
filing federal case
MS Phone conferences with James Bopp, Jr. 0.40 108.00

regarding next steps, Younger abstention 270.00/hr
1/24/2022 JB Review draft Preliminary Injunction outline; 0.40 252.00

approve 630.00/hr
MS Research legal issues, draft outline; email to 2.50 675.00

James Bopp, Jr. for approval; email exchange 270.00/hr
regarding
additional challenges; Annuity Act
1/25/2022 JB E-mail exchange with Melena Siebert regarding 0.30 189.00

additional challenge 630.00/hr
MS Phone conference with local counsel regarding 0.30 81.00

district court choices 270.00/hr
Hrs/Rate Amount
1/25/2022 MS Research, draft memo In Support of Preliminary 6.00 1,620.00

Injunction; email exchange with client and 270.00/hr
James Bopp, Jr.
regarding candidacy filing
JB Review candidacy filing, e-mail exchange 0.40 252.00

regarding candidacy filing 630.00/hr
JB Review Amnesty Act, e-mail exchange with 0.40 252.00

Melena Siebert regarding Amnesty Acts 630.00/hr

Injunction 270.00/hr

JB Review email exchange regarding LDF 0.40 252.00

630.00/hr
JPG Email exchange regarding Legal Defense Fund 0.40 190.00

475.00/hr

JB Review news report regarding primary extension 0.30 189.00

630.00/hr
1/29/2022 MS Draft motion for Preliminary Injunction, motion 3.20 864.00

to expedite, motion to consolidate, corporate 270.00/hr
disclosure statement, civil cover sheet, summons
MS Draft Bopp and Siebert Notice of Special 0.40 NO CHARGE

Appearances (PHV), CM/ECF Registration 270.00/hr
forms
JB Review draft of Preliminary Injunction memo 0.60 378.00

630.00/hr
Hrs/Rate Amount
1/30/2022 JB Revise Preliminary Injunction memo draft 1.20 756.00

630.00/hr
JB Revise complaint draft 0.80 504.00

630.00/hr
JB Revise draft Motion to Expedite 0.30 189.00

630.00/hr
1/31/2022 MS Phone conferences with local counsel regarding 0.30 81.00

filing, edits 270.00/hr

regarding edits to filings 270.00/hr

regarding revision of complaint and edits to 630.00/hr
filings
MS Draft press release, phone conference with 1.20 NO CHARGE

client regarding same 270.00/hr
MS Finalize, edit, file complaint, Preliminary 3.00 810.00

Injunction motion and memo, Motion to 270.00/hr
Expedite, Motion to Consolidate, and all
administrative filings related to same
JB Revise draft press release 0.40 NO CHARGE

630.00/hr
2/1/2022 MS Phone conference with local counsel regarding 0.50 NO CHARGE

service, edit affidavit of service, various 270.00/hr
administrative filings
MS E-mail exchanges with client, James Bopp, Jr. 0.60 NO CHARGE

regarding changes to press release 270.00/hr
Hrs/Rate Amount
2/1/2022 JB Revise draft press release; phone conference 0.30 NO CHARGE

and email exchange with Melena Siebert 630.00/hr
regarding changes to press release
2/2/2022 JB Review court order regarding expedition; email 0.40 252.00

client 630.00/hr
For professional services rendered 73.40 $26,100.50

Additional charges:
Qty/Price
1/11/2022 Cost advanced for WestLaw computer assisted legal 16 48.00

research--research law on NC candidacy challenge $3.00
statute

research--research law on Amnesty Act of 1872 $3.00

research--researchYounger abstention when state $3.00
proceeding stayed

research--research caselaw In Support of Preliminary $3.00
Injunction

Injunction

Injunction

Injunction
Qty/Price Amount

research--research law for Preliminary Injunction, $3.00
motion to expedite, motion to consolidate
Total costs $534.00
Total amount of this bill $26,634.50
Balance due $26,634.50
Attorney Summary
Name Hrs/Rate Rate
---=-~ Amount
--~~=
James Bopp, Jr. 18.80 630.00 $11,844.00
James Bopp, Jr. 1.30 0.00 $0.00
Jeffrey P. Gallant 2.90 475.00 $1,377.50
Melena Siebert 47.70 270.00 $12,879.00
Melena Siebert 2.70 0.00 $0.00
Exhibit 3
Cawthorn Invoice Mar. 25, 2022
JAMES BOPP, JR.
Case 2:22-cv-00554-JRS-MG
[email protected]
Document 9-3 .Bopp
'.fHE Filed 12/07/22 Page 2 of
LAVV Fm.1w, PC 13 PageID #: 145
ATTORNEYS AT LAW
11!E NA 'DONAL BUJLDJNG

1 South Sixth Stre.ct
TERRE HAUD2, INDIANA 47807-3510
www.bopplaw.CDrn
INVOICE
March 25, 2022
Madison Cawthorn
Thomas Datwyler
PO Box 183
Hudson, WI 54016
In Reference To:Admjnistrative Challenge to Candidacy and Suit vs. NCSBE
Hrs/Rate Amount
2/3/2022 MS Phone conferences with James Bopp, Jr. 0.20 54.00
regarding legal arguments for reply, emphasis- 270.00/hr
on public interest
MS Call court clerk, draft, file motion for refund for 0.90 NO CHARGE
fees paid electronically 270.00/hr
MS E-mail exchanges with client regarding required 0.90 243.00
explanation, billing records for LEF, email and 270.00/hr
phone conference with Jeffrey P. Gallant
regarding same ·
Hrs/Rate Amount
2/3/2022 JB Phone conferences with Melena Siebert 0.60 378.00

regarding legal arguments for reply, emphasis 630.00/hr
on public interest; review email exchange
JPG Phone conference with Melena Siebert 0.20 95.00

regarding billing records 475.00/hr
2/4/2022 MS Draft summary of notes for research needs for 0.90 243.00
reply 270.00/hr
2/7/2022 JB Phone conference with counsel from Intervenor 0.20 126.00

regarding intervention 630.00/hr
JB Review Motion to Intervene and brief 0.80 504.00

630.00/hr
JB Review proposed Intervention Opposition to 1.20 756.00

Preliminary Injunction 630.00/hr
2/8/2022 MS Phone conference with James Bopp, Jr. 0.20 54.00

regarding Reply In Support of Preliminary 270.00/hr
Injunction
JB Review State Opposition to Consolidation 0.40 252.00

630.00/hr
JB Review State Opposition to Preliminary 1.10 693.00


Injunction
2/9/2022 MS E-mail to Michael Massie regarding response to 0.50 135.00

motion to intervene, phone conference 270.00/hr
regarding same
Hrs/Rate Amount
2/9/2022 MS Send email to client with update on motion to 0.30 81.00

intervene, next steps, phone conference with 270.00/hr
client regarding same
MS Draft, research Reply In Support of Preliminary 4.60 1,242.00

Injunction, phone conference with local counsel 270.00/hr
regarding same
MM Review prior emails and make notes from 0.40 66.00

Melena Siebert and James Bopp, Jr. regarding 165.00/hr
research and drafting assignment
MM Briefly review Motion to Intervene 0.10 16.50

165.00/hr
MM Review case documents 0.30 49.50

165.00/hr
MM Review Rules of Civil procedure regarding 0.20 33.00

intervention 165.00/hr
MM Review notes of decisions regarding when 0.50 82.50

representation is considered adequate 165.00/hr
MM Review notes of decisions regarding when 0.10 16.50

representation is considered adequate 165.00/hr
MM Research case law on when permissive 0.10 16.50

intervention is allowed 165.00/hr
MM Phone conference with Melena Siebert 0.10 16.50

regarding response to motion to intervene and 165.00/hr
results of primarily research
MM Review case law on intervention of a right 1.40 231.00

165.00/hr
MM Review case law on intervention of a right, take 0.90 148.50

notes 165.00/hr
Hrs/Rate Amount
2/9/2022 MM Take notes on Motion to Intervene 0.70 115.50
165.00/hr
MM Draft Response to Motion to Intervene 1.50 247.50

165.00/hr
MM Draft Response to Motion to Intervene; phone 1.60 264.00

conference with Melena Siebert 165.00/hr
MS Phone conference with Michael Massie 0.10 27.00
regarding response to motion to intervene and 270.00/hr
results of primarily research
2/10/2022 MM Draft Response to Motion to Intervene, review 3.40 561.00

case law on adequate representation, review 165.00/hr
motion to intervene
MM Draft Response to Motion to Intervene, email 0.60 99.00

Melena Siebert 165.00/hr
MM Make suggested changes to Response to Motion 0.90 148.50

to Intervene, look up case law on compliance 165.00/hr
with Rule 24(c)

regarding Reply in Support of Motion to 165.00/hr
Consolidate

Injunction, Reply In Support of Motion to
Consolidate, Response to Motion to Intervene
MS Edit Reply In Support of Preliminary Injunction 4.80 1,296.00

270.00/hr
MS Review, edit Response to Motion to Intervene 1.00 270.00
270.00/hr
Madison Cawthorn
Page 5
Hrs/Rate Amount
regarding argument for Replies and Response 630.00/hr
JB Review draft of Opposition to Intervene; 0.70 441.00
suggest changes 630.00/hr
regarding revised briefs 630.00/hr
regarding Reply in Support of Motion to 270.00/hr
Consolidate
2/11/2022 MM Review Motion to Consolidate 0.10 16.50

165.00/hr
MM Review and take notes on Response in 0.20 33.00
Opposition to Motion to Consolidate 165.00/hr
MM Review case law cited in Response in 0.20 33.00
opposition to Motion to Consolidate 165.00/hr
MM Research case law on when consolidation of a 0.10 16.50
Preliminary Injunction with the trial on the 165.00/hr
merits is proper
MM Review case law on when consolidation is 0.30 49.50

proper 165.00/hr
MM Draft Reply in Support of Motion to Consolidate 0.80 132.00
165.00/hr
MM Review Response to Motion to Consolidate 0.10 16.50
165.00/hr
MM Draft Reply in Support of Motion to Consolidate 1.10 181.50
165.00/hr
Madison Cawthorn
Page 6
Hrs/Rate Amount
2/11/2022 MS Phone conferences with James Bopp, Jr. 0.10 27.00
Injunction, Reply In Support of Motion to
Consolidate, Response to Motion to Intervene
MS Edit and file Reply In Support of Preliminary 2.50 675.00

Injunction, Response to Motion to Intervene, 270.00/hr
Reply In Support of Motion to Consolidate
JB Revise Preliminary Injunction Reply; phone 0.40 252.00

conference with Melena Siebert regarding 630.00/hr
revision
JB Review Reply to Motion to Consolidate; phone 0.50 315.00

2/16/2022 JB Review email from local counsel on update 0.20 126.00
630.00/hr
2/17/2022 JB Review Reply to Motion to Intervene; revise 0.50 315.00
630.00/hr
letter to Bob Orr 630.00/hr
JB Review email exchange regarding Trust 0.30 189.00
630.00/hr
redistricting issues 270.00/hr
MS Videoconference with client, trustee, local 0.50 135.00
counsel regarding legal expense fund trust setup 270.00/hr
MS Phone conference with client regarding legal 0.10 27.00
expense fund trust setup, redistricting special 270.00/hr
master issue
Madison Cawthorn
Page 7
Hrs/Rate Amount
regarding redistricting special master issue 270.00/hr
regarding special master issue 630.00/hr
regarding Bob Orr letter; revise same; review 630.00/hr
email exchange regarding same
JB E-mail exchange regarding press release 0.40 NO CHARGE

630.00/hr
MS Research, review NC trust law 0.50 135.00
270.00/hr
MS Phone conference with client regarding NC 0.10 27.00
trust law 270.00/hr
filing legal expense fund trust documents 270.00/hr
MS Draft press release regarding Bob Orr, phone 1.30 NO CHARGE
conference with client regarding same 270.00/hr
JB E-mail exchange regarding ORR letter and 0.40 NO CHARGE
press release 630.00/hr
regarding Bob Orr letter 270.00/hr
2/21/2022 JB Review Order on Motion to Consolidate 0.30 189.00
630.00/hr
JB Review Order on Intervention 0.40 252.00
630.00/hr
JB Review Order on Status Conference and Hearing 0.10 63.00
630.00/hr
Hrs/Rate Amount
2/21/2022 MS Review denial of Motion to Intervene 0.50 135.00
270.00/hr
MS E-mail to client regarding denial of motion to 0.20 54.00
intervene, follow up phone conference with 270.00/hr
client regarding same
2/22/2022 MS Attend Status Conference, follow up phone 0.70 189.00

conference with James Bopp, Jr., local counsel; 270.00/hr
email exchange regarding same
JB E-mail exchange regarding Status Conference 0.30 189.00

630.00/hr
JB Attend Status Conference 0.40 252.00
630.00/hr
JB Phone conference with Melena Siebert and 0.30 189.00
local counsel regarding next steps 630.00/hr
2/23/2022 MS Review motion to dismiss, organize for 2.80 756.00
potential response, phone conference with 270.00/hr
James Bopp, Jr. regarding Amnesty Act, motion
to dismiss and response
JB Review Motion to Dismiss; phone conference 0.90 567.00

with Melena Siebert regarding new issues and 630.00/hr
response
JB E-mail from Melena Siebert with questions; 1.10 693.00

research; review amicus filing 630.00/hr
JB Review pleading; review research for hearing 2.30 1,449.00
630.00/hr
regarding potential response to Motion to 270.00/hr
Dismiss, Notice
Hrs/Rate Amount
2/24/2022 MS Research, Draft Response to Notice ofNCSBE 3.60 972.00

Action, send same to James Bopp, Jr. for review 270.00/hr
MS Phone conference with client regarding 0.10 27.00

redistricting issue, refiling candidacy 270.00/hr
MM Review Order Denying Motion to Intervene and 0.20 33.00

Order Granting Motion to Consolidate 165.00/hr
JB Prepare for hearing 1.60 1,008.00

630.00/hr
JB Review Motion to Dismiss; phone conference 0.60 378.00

with Melena Siebert regarding response to 630.00/hr
Motion to Dismiss
JB Review email exchange with local counsel 0.30 189.00

regarding hearing 630.00/hr

regarding letter for NCSBE and response 630.00/hr

Notice and letter 630.00/hr

regarding Response to Notice; review email 630.00/hr
exchange regarding Response
JB Review court order; phone conference with 0.40 252.00

Melena Siebert regarding Response to Notice 630.00/hr

regarding letter for NCSBE and response 270.00/hr
2/25/2022 JB Revise Response to Notice 0.50 315.00

630.00/hr
Hrs/Rate Amount

regarding Response and next steps 630.00/hr
JB Prepare for Status Conference 0.80 504.00

630.00/hr
JB Attend Status Conference 0.40 252.00

630.00/hr
JB Phone conference with Melena Siebert and 0.70 441.00

Blake regarding next steps 630.00/hr

regarding Response and next steps 270.00/hr
MS Phone conference with James Bopp, Jr. and 0.70 189.00

Blake regarding next steps 270.00/hr
2/28/2022 MS Review NC statutes for potential challenge 0.70 189.00

process after primary 270.00/hr
MS Research, draft letter to NCSBE regarding 1.20 324.00

Challenger who lives in new district 270.00/hr

regarding current challenge and candidate 630.00/hr
filing; email exchange regarding candidate filing

regarding current challenge and candidate 270.00/hr
filing; email exchange regarding candidate filing

Additional charges:
Qty/Price Amount
2/1/2022 Cost advanced for FedEx to deliver documents to Clerk 1 27.41

of Court--US District Court--310 New Bern $27.41
Ave-Raleigh, NC 27601
Cost advanced for FedEx to deliver documents from 1 27.41

James Bopp, Jr. to Clerk of Court--US District $27.41
Court--310 New Bern Ave-Raleigh, NC 27601

research--research case law for permissive intervention $3.00

research--research case law for Reply In Support of $3.00
Preliminary Injunction

research--research case law for Reply In Support of $3.00
Preliminary Injunction

research--research NCSBE statutory authority to $3.00
invalidate Challenge
Total costs $138.82
Previous balance $26,634.50
Attorney Summary
Name Hrs/Rate Rate
--== Amount
----=-===
James Bopp, Jr. 22.50 630.00 $14,175.00
Name Hrs/Rate Rate Amount

James Bopp, Jr. 0.80 0.00 $0.00
Jeffrey P. Gallant 0.20 475.00 $95.00
Melena Siebert 31.60 270.00 $8,532.00
Michael Massie 16.00 165.00 $2,640.00
Exhibit 4
Cawthorn Invoice Apr. 26, 2022
JAME S BOPP, JR.

[email protected]
ATTORNEYS AT LAW
THE NATIONAL BUILDING

I South Sixth Street
www.bopplaw.com
INVOICE
April 26, 2022
Madison Cawthorn
Thomas Datwyler
PO Box 183
Hudson, WI 54016
In Reference ToCawthorn vs. NCSBE
Hrs/Rate Amount
regarding notice to court of new challenges, 270.00/hr
potential letter to NCSBE
MS Review new challenges, review NCSBE notice 1.30 351.00

to Court, draft notice requesting hearing, review 270.00/hr
Court order regarding hearing
JB Review new candidate challenges; email 0.80 504.00

exchange regarding challenges 630.00/hr
Hrs/Rate Amount

regarding response to new challenges 630.00/hr
JB Review Notice to Court 0.30 189.00

630.00/hr

regarding preparing request for hearing; revise 630.00/hr
draft; review draft of Notice and request
JB Review order setting hearing on Friday; email 0.50 315.00

exchange with various parties regarding hearing 630.00/hr

regarding hearing preparation needs 270.00/hr
MS Gather materials for hearing, research 1.80 486.00

Congressional Record regarding Amnesty Act 270.00/hr
of 1872

hearing 270.00/hr
JB Review order regarding amicus brief 0.20 126.00

630.00/hr
JB Review email exchange regarding hearing 0.30 189.00

630.00/hr
JB Preparation for hearing 2.50 1,575.00

630.00/hr

regarding research material for hearing 630.00/hr
JB Review material from Melena Siebert 1.00 630.00

630.00/hr
Hrs/Rate Amount
3/3/2022 JB Review court order 0.20 126.00
630.00/hr
JB Review email exchange regarding hearing 0.40 252.00

630.00/hr
JB Travel and preparation for hearing 5.10 3,213.00

630.00/hr

regarding research material for hearing 270.00/hr
3/4/2022 MS Prepare for hearing, attend hearing 1.70 459.00

270.00/hr
MS Draft press release, send to James Bopp, Jr. for 0.60 NO CHARGE
review 270.00/hr
MS Phone conference with client, local counsel 0.20 54.00

regarding hearing, court's decision 270.00/hr
regarding hearing 270.00/hr
JB Preparation for oral argument; phone 3.50 2,205.00

material and thoughts on issues in hearing
JB Attend oral argument 1.00 630.00

630.00/hr

regarding argument 630.00/hr
JB Review court minutes entry 0.20 126.00
630.00/hr
Hrs/Rate Amount
3/4/2022 JB Phone conference with Melena Siebert 0.60 NO CHARGE
regarding press release; review draft press 630.001hr
release; approve
3/9/2022 MS Review Emergency Motion to Stay, Research 3.70 999.00

case law for response regarding standard of 270.00/hr
review for denial of motion to intervene,
standing, ability to appeal if intervention denied
MS File Bopp appearance, Siebert application for 1.00 NO CHARGE

admission to 4th Circuit 270.00/hr

regarding response to emergency motion to 270.00/hr
stay, research needs regarding same
JB Review notice of appeal by intervenor 0.30 189.00

630.00/hr
JB Review Motion for Stay by intervenor 0.90 567.00

630.00/hr
JB E-mail exchange and phone conference with 0.60 378.00

Melena Siebert regarding possible response to 630.00/hr
Motion to Stay
JB Review Melena Siebert research regarding Stay 0.50 315.00

630.00/hr
JB Research on cases cited in Stay request; phone 2.50 1,575.00

cases; review cases from Melena Siebert
JB Review court order on response; phone 0.50 315.00

response
JB Preparation of outline for response 1.20 756.00

630.00/hr
Hrs/Rate Amount
3/9/2022 JB Numerous phone conferences with Melena 0.90 567.00

Siebert regarding research and discuss issues 630.00/hr
for response
JB Review email exchange regarding research for 0.40 252.00

response 630.00/hr

regarding cases 270.00/hr

regarding response 270.00/hr
MS Numerous phone conferences with James Bopp, 0.90 243.00

Jr. regarding research and discuss issues for 270.00/hr
response
3/10/2022 REC E-mail from James Bopp, Jr. regarding briefing 0.10 53.00
conference 530.00/hr
JB E-mail to Richard E. Coleson regarding briefing 0.10 63.00

REC E-mail from Melena Siebert regarding briefing 0.10 53.00

MS E-mail to Richard E. Coleson regarding briefing 0.10 27.00

REC Videoconference with James Bopp, Jr., Melena 1.10 583.00

Siebert, and Emma Shirley regarding response 530.00/hr
to intervenors' stay motion in 4th Circuit
JB Videoconference with Richard E. Coleson, 1.10 693.00

Melena Siebert, and Emma Shirley regarding 630.00/hr
response to intervenors' stay motion in 4th
Circuit
Hrs/Rate Amount
3/10/2022 ES Videoconference with Richard E. Coleson, 1.10 181.50

Melena Siebert, and James Bopp, Jr. regarding 165.00/hr
Circuit
MS Videoconference with Richard E. Coleson, 1.10 297.00

James Bopp, Jr. and Emma Shirley regarding 270.00/hr
Circuit
REC Review and annotate preliminary injunction 1.40 742.00

memo regarding Fourteenth Amendment 530.00/hr
section 3; review and annotate part of transcript
of oral argument regarding same
REC Review and annotate part of oral-argument 4.30 2,279.00

transcript; make briefing notes; consider 530.00/hr
arguments
REC E-mails with Melena Siebert regarding brief 0.10 53.00

outline and word allotments for briefers 530.00/hr
REC Review and annotate rest of transcript of oral 2.10 1,113.00

argument and the court's ruling; make briefing 530.00/hr
notes and consider arguments
MS E-mails with Richard E. Coleson regarding 0.10 27.00

brief outline and word allotments for briefers 270.00/hr
ES Research regarding state procedure for 4.50 742.50

challenge to candidate, drafting module 165.00/hr

regarding work assignment 165.00/hr
MM Review Intervenors Request for Emergency Stay 0.10 16.50

165.00/hr
Hrs/Rate Amount
3/10/2022 MM Review Response to Motion to Intervene 0.40 66.00

165.00/hr
MM Review Order Denying Motion to Intervene 0.10 16.50

165.00/hr
MM Take notes on Response to Motion to Intervene 0.90 148.50

and Order Denying Motion to Intervene 165.00/hr
MM Review case law cited in Response to Motion to 0.80 132.00

Intervene 165.00/hr
MM Review case law cited in Order denying Motion 0.50 82.50

to Intervene 165.00/hr
MM Review outline of Response to Emergency 0.40 66.00

Request for Stay 165.00/hr
MM Review case law on motions to intervene 0.80 132.00

165.00/hr
MM Draft Outline for Section on Response 1.10 181.50

165.00/hr

regarding cognizable interest of challengers 270.00/hr
MS Get Application for Admission notarized, file 0.50 NO CHARGE

with 4th Circuit 270.00/hr
MS Draft Response Outline, framework for 2.40 648.00

sections, email to James Bopp, Jr., Richard 270.00/hr
Coleson, Michael Massie, Emma Shirley
regarding same
MS Research and draft Federal Rule of Appellate 1.80 486.00

Procedure Rule 8 Module 270.00/hr
Hrs/Rate Amount
3/10/2022 MS Review district court opinion 0.50 135.00

270.00/hr



regarding outline and arguments 630.00/hr
JB E-mail exchange with client regarding Stay 0.30 189.00

630.00/hr
JB Review Melena Siebert email regarding 0.30 189.00

response requests 630.00/hr
JB E-mail exchange with Melena Siebert regarding 0.30 189.00

argument in response 630.00/hr
JB Review order granting Preliminary Injunction; 1.30 819.00

regarding order

regarding cognizable interest of challengers 630.00/hr


regarding outline and arguments 270.00/hr
MS E-mail exchange with James Bopp, Jr. 0.30 81.00

regarding argument in response 270.00/hr

regarding order granting Preliminary Injunction 270.00/hr
Hrs/Rate Amount
3/11/2022 REC Download and print district court's written 0.10 NO CHARGE
preliminary injunction order 530.00/hr
REC Review and annotate portions of court's written 0.70 371.00

order relevant to briefing 1872 Act 530.00/hr
REC Prepare and send e-mail to James Bopp, Jr. 0.20 106.00
regarding requested conference regarding 530.00/hr
briefing
REC Work on 1872 Act argument for stay opposition 2.40 1,272.00
530.00/hr
REC Phone conference with James Bopp, Jr. 0.40 212.00

regarding argument for stay opposition 530.00/hr
JB Phone conference with Richard E. Coleson 0.40 252.00

regarding argument for stay opposition 630.00/hr
REC Work on 1872 Act argument for stay opposition 4.20 2,226.00
530.00/hr
ES Phone conference with Melena Siebert 0.70 115.50

regarding contest procedure and background of 165.00/hr
case
ES Drafting section on contest procedure, 4.00 660.00

researching and drafting remaining sections 165.00/hr
under irreparable harm, reviewing past filings,
Bluebook cites
MM Draft Module on Denial of Motion to Intervene 1.10 181.50

165.00/hr
MM Review case law on motion to intervene 0.30 49.50
standard of review 165.00/hr
Hrs/Rate Amount
3/11/2022 MM Draft Module on Denial of Motion to Intervene, 2.10 346.50

read case law on motion to intervene, review 165.00/hr
order denying motion to intervene
MM Edit Module on Denial of Motion to Intervene, 1.10 181.50

email to Melena Siebert 165.00/hr
MS Draft, edit response to emergency motion to 5.30 1,431.00

stay, research case law regarding same 270.00/hr
MS Phone conference with Emma Shirley regarding 0.70 189.00

NC law on challenges after primary, general 270.00/hr

regarding response to emergency motion to stay 270.00/hr
JB E-mail exchange with counsel for amicus curiae 0.30 189.00

630.00/hr
JB Review official transcript 0.60 378.00

630.00/hr
JB Review supplemental affidavit; phone 0.40 252.00

conference with Melena Siebert regarding filings 630.00/hr
JB Review amicus brief; send to Richard E. 0.70 441.00

Coleson 630.00/hr
JB Review court order on amicus brief 0.20 126.00

630.00/hr
JB Review Melena Siebert email regarding citation 0.30 189.00

intervention 630.00/hr

regarding response to emergency motion to stay 630.00/hr
3/12/2022 REC Work on 14th Amendment, Section 3 portion of 3.70 1,961.00

stay response 530.00/hr
Madison Cawthorn
Page 11
Hrs/Rate Amount
3/12/2022 REC
Work on 14th Amendment, Section 3 portion of
stay response 2.50 1,325.00
530.00/hr
REC
E-mail to James Bopp, Jr. regarding draft review
0.10 53.00
530.00/hr
JB
E-mail from Richard E. Coleson regarding draft
review 0.10 63.00
630.00/hr
REC
E-mails with Melena Siebert with response draft
0.10 53.00
530.00/hr
MS
E-mails with Richard E. Coleson with response
draft 0.10 27.00
270.00/hr
REC Revise unclear sentence in my part of response
and circulate for review 0.30 159.00
530.00/hr
MS
Draft, edit response to emergency motion to
stay, research case law regarding same, send 1.30 351.00
same to James Bopp, Jr. for review 270.00/hr
JB
Phone conference with Richard E. Coleson
0.30 189.00
regarding his module for brief; review draft
Amnesty Act module 630.00/hr
3/13/2022 MS
Draft, edit response to emergency motion to
stay, module on other constitutional claims, 0.90 243.00
send same to James Bopp, Jr. for review 270.00/hr
JB
Revise draft; review Revise email regarding
edit; email Melena Siebert regarding module on 1.50 945.00
additional claims 630.00/hr
JB
Edit brief; incorporate additions from Melena
Siebert and Richard E. Coleson 5.50 3,465.00
630.00/hr
JB Review and edit my draft
1.50 945.00
630.00/hr
Hrs/Rate Amount
3/14/2022 REC Review copies of emails between James Bopp, 0.20 106.00
Jr. and Melena Siebert regarding stay opposition 530.00/hr
REC Phone call from Melena Siebert regarding 0.20 106.00

arguments for brief 530.00/hr
MS Phone call to Richard E. Coleson regarding 0.20 54.00

arguments for brief 270.00/hr
REC Review part of response draft and add edits; 1.10 583.00
prepare comments regarding same for Melena 530.00/hr
Siebert
REC E-mails with Melena Siebert regarding edits to 0.10 53.00

response draft 530.00/hr
MS E-mails with Richard E. Coleson regarding 0.10 27.00

edits to response draft 270.00/hr
REC Research 4th Circuit cases for possible holdings 0.30 159.00
on investigation standards 530.00/hr
REC Check docket regarding filing of stay response; 0.50 265.00

download brief and review in part 530.00/hr
MM Edit Module on Denial of Motion to Intervene 0.30 49.50

for citations, email to Melena Siebert 165.00/hr
MS Edit, finalize response to emergency motion to 5.20 1,404.00

stay, file same with 4th Court of Appeals 270.00/hr

regarding response, NC Attorney General office 270.00/hr
response
JPG Proof, edit response to emergency motion to stay 1.00 475.00

475.00/hr
Hrs/Rate Amount

regarding Attorney General phone conference 630.00/hr
JB Review brief; phone conference with Melena 2.00 1,260.00

Siebert regarding research and edits 630.00/hr

regarding revision 630.001hr
JB Phone conference with Attorney General office 0.30 189.00

regarding intervenor 630.001hr

regarding research and edits 270.00/hr

regarding revision 270.00/hr
3/15/2022 ES Prepare pro hac vice for Jeffrey P. Gallant, 1.70 NO CHARGE
check Public for models, email Melena Siebert 165.00/hr
for confirmation
JPG E-mail exchange regarding filing a fee petition 1.10 522.50

in Cawthorn.challenge; check rules 475.00/hr
JB Review NC GOP amicus brief 0.70 441.00

630.00/hr
3/16/2022 ES Complete pro hac vice for Jeffrey P. Gallant; 1.10 NO CHARGE
email Melena Siebert for confirmation on pro 165.00/hr
hac vice process, phone conference with Jeffrey
P. Gallant to discuss pro hac vice application
JB E-mail exchange with Jeffrey P. Gallant 0.30 189.00

regarding filing attorney fee petition 630.00/hr
3/17/2022 MS Review 4th Circuit Order on Limited remand, 1.10 297.00

phone conferences with James Bopp, Jr. 270.00/hr
regarding same, begin research regarding same
Madison Cawthorn
Page 14
Hrs/Rate Amount
3/17/2022 JB Review 4th Circuit orders; phone conference
0.80 504.00
with Melena Siebert regarding order decision
630.00/hr
(2x); email to client; phone conference with
Josh and Melena Siebert regarding next steps
JB E-mail exchange with opposing counsel
0.40 252.00
regarding consent to 2nd Intervention motion;
630.00/hr
phone conference with Melena Siebert
JB Review Motion to Intervene

0.90 567.00
630.00/hr
JPG E-mail regarding fees
0.10 47.50
475.00/hr
3/18/2022 JB
Preparation of outline for response; phone
1.30 819.00
conference with Melena Siebert regarding
response 630.00/hr
JB Research regarding Motion to Intervene

0.50 315.00
630.00/hr
JB
Phone conference with Melena Siebert; review
court order 0.40 252.00
630.00/hr
MS
Phone conference with James Bopp, Jr.
0.80 216.00
regarding outline, draft of response to renewed
motion to intervene, research needs 270.00/hr
MS
Research intervention law regarding what is
2.90 783.00
"interest'' and interplay with intervention within
context of appeal 270.00/hr
MS Review renewed motion to intervene

0.50 135.00
270.00/hr
3/2 l /2022 JB Review affidavit
0.50 315.00
630.00/hr
Madison Cawthorn
Page 15
Hrs/Rate Amount
3/22/2022 MM
Phone conference with Melena Siebert
regarding research assignment 0.20 33.00
165.00/hr
MM Review Renewed Motion for Intervention
0.80 132.00
165.00/hr
MM Review documents in legal research folder
0.40 66.00
165.00/hr
MM Review Notes of Decisions for Rule 24
0.60 99.00
165.00/hr
MM Review case law on intervention
2.80 462.00
165.00/hr
MM E-mail Melena Siebert regarding results of
research 0.60 99.00
165.00/hr
MS Phone conference with Michael Massie
regarding research assignment 0.20 54.00
270.00/hr
3/23/2022 MM
Phone conference with Melena Siebert
0.10 16.50
regarding Response to Renewed Motion to
Intervene 165.00/hr
MM E-mail from Melena Siebert regarding

Response to Renewed Motion to Intervene 0.20 33.00
165.00/hr
MM
Review Renewed Motion to Intervene
1.00 165.00
165.00/hr
MM
Research case law on protectable property
interests 0.10 16.50
165.00/hr
MM Review case law on protectable property
interests 2.20 363.00
165.00/hr
MM
Review case law on Intervention as of right
0.80 132.00
165.00/hr
Hrs/Rate Amount
3/23/2022 MM Draft outline on Response to Renewed Motion 1.10 181.50


regarding renewed motion to intervene, draft 270.00/hr
follow up email with notes on drafting,
arguments to James Bopp, Jr. and Michael
Massie regarding same
JB Review research regarding new intervention 0.50 315.00

630.00/hr
JB E-mail exchange with Jeffrey P. Gallant 0.40 252.00

regarding attorney fee petition 630.00/hr
JPG Calendar motion/memo; emails to Melena 0.40 190.00

Siebert, James Bopp, Jr. 475.00/hr
JPG Work on motion, memo, supporting documents 6.50 3,087.50

475.00/hr
3/24/2022 MM Draft outline for Response to Renewed Motion 0.70 115.50

MM Review Renewed Motion to Intervene, review 1.20 198.00

amicus brief 165.00/hr
MM Review case law on Intervention 1.60 264.00

165.00/hr
MM Draft Response to Renewed Motion to Intervene 0.50 82.50

165.00/hr

regarding Response to Renewed Motion to 165.00/hr
Intervene
MM Draft Response to Renewed Motion to 1.60 264.00

Intervene, review case law on intervention 165.00/hr
Hrs/Rate Amount
3/24/2022 MM Draft Response to Renewed Motion to 1.50 247.50

Intervene, review renewed motion to intervene 165.00/hr
MS Phone conference with Jeffrey P. Gallant 0.20 NO CHARGE

regarding notice of deficiencies from court 270.00/hr

regarding drafting outline for response to 270.00/hr
renewed motion to intervene
JB Review draft outline of Intervention Response 0.50 315.00

630.00/hr
JB Review email exchange regarding petition for 0.40 252.00

attorney fee rates 630.00/hr
JB Review draft Motion for Attorney Fees and 0.70 441.00

Memo 630.00/hr
JPG Work on motion, memo with fair estimate 4.30 2,042.50

475.00/hr
JPG Phone conference with Melena Siebert 0.20 95.00

regarding certificate of service, page/word 475.00/hr
certification
3/25/2022 MM Review case law on motion to intervene 0.90 148.50

165.00/hr
MM Draft Response to Renewed Motion to Intervene 4.60 759.00

165.00/hr
MM Review Renewed Motion to Intervene and 0.40 66.00

Defendant's Amicus Brief 165.00/hr
MM Draft Response to Renewed Motion to 1.80 297.00

Intervene, review case law on motion to 165.00/hr
intervene
Madison Cawthorn
Page 18
Hrs/Rate Amount
3/25/2022 MS
Phone conference with Jeffrey P. Gallant
0.30 81.00
regarding response to notice of deficiency
270.00/hr
JB Review court order; email exchange regarding
correction 0.40 252.00
630.00/hr
JB Review draft Response to Motion
0.40 252.00
630.00/hr
JPG Review Notice of Deficiency, draft response,
3.40 1,615.00
draft proposed scheduling order, draft
475.00/hr
supplement regarding efforts to confer with
opposing counsel
JPG Various emails and phone conference with

1.10 522.50
attorney Josh Howard regarding response to
475.00/hr
Notice of Deficiency, contact with opposing
counsel
JPG Filing response, proposed order, and send

proposed order to chambers 0.60 285.00
475.00/hr
JPG Phone conference with Melena Siebert
regarding response to notice of deficiency 0.30 142.50
475.00/hr
3/26/2022 MS
Draft, edit Response to Renewed Motion to
Intervene 1.50 405.00
270.00/hr
3/27/2022 MS
Draft, edit Response to Renewed Motion to
Intervene 6.40 1,728.00
270.00/hr
3/28/2022 JB
Revise Brief in Opposition to Motion to Amend
3.50 2,205.00
630.00/hr
MS
Finalize, file Response to Renewed Motion to
Intervene 1.20 324.00
270.00/hr
JB Phone conference with Melena Siebert
regarding revision 0.30 189.00
630.00/hr
Hrs/Rate Amount

regarding revision; final revision of Intervention 630.00/hr
Opposition
JB Review Attorney General response to Motion to 0.40 252.00

Intervene 630.00/hr


3/29/2022 JB Review court order regarding attorney fees 0.20 126.00

630.00/hr
JPG Review order on attorney's fees schedule, phone 0.30 142.50

conference with James Bopp, Jr. 475.00/hr
JB Phone conference with James Bopp, Jr. 0.10 63.00

regarding order on attorney's fees 630.00/hr
3/30/2022 MS Phone conference with James Bopp, Jr., local 0.20 54.00
counsel regarding court's order for "stay" of 270.00/hr
constitutional claims
JB Review court order regarding Stay; phone 0.40 252.00

JB Review order denying intervention; phone 0.70 441.00

conference with Melena Siebert regarding order 630.00/hr

regarding order denying intervention 270.00/hr
3/31/2022 JB E-mail exchange with opposing counsel 0.30 189.00

regarding Stay request 630.00/hr
Hrs/Rate Amount
3/31/2022 JB Review notice of appeal 0.30 189.00

630.00/hr
JB Review Motion to Stay; phone conference with 0.80 504.00

Melena Siebert regarding Motion to Stay 630.00/hr
JB Review 4th Circuit Order regarding Response 0.30 189.00

630.00/hr

Additional charges:
Qty/Price

research--research Amnesty Act of 1898 $3.00
Travel expense for James Bopp, Jr. to attend Cawthorn 1 1,928.13

Preliminary Injunction Hearing from 03-03-22 through $1,928.13
03-04-22--in Wilmington, NC

research--research for Response to Emergency Motion $3.00
to Stay
3/10/2022 Cost advanced for 4th Circuit Court of Appeals 1 228.00

Admission Fee for Melena Siebert--paid online at $228.00
pay.gov--on 03-10-22--payable to US Court of
Appeals--Fourth Circuit-Tracking Id:
A04-71941-l 33--MC
Cost advanced for WestLaw computer assisted legal 36 108.00

to Stay

to Stay
Qty/Price Amount

to Stay

to Stay
3/18/2022 Cost advanced for FedEx to deliver legal documents to 1 26.80

Clerk of the Court--310 New Bern Avenue--Raleigh, $26.80
NC 27601
Total costs $2,485.93
Attorney Summary
Name Hrs/Rate Rate ---''-="'==
Amount
Emma Shirley 10.30 165.00 $1,699.50
Emma Shirley 2.80 0.00 $0.00
James Bopp, Jr. 63.10 630.00 $39,753.00
James Bopp, Jr. 0.60 0.00 $0.00
Jeffrey P. Gallant 19.30 475.00 $9,167.50
Melena Siebert 51.30 270.00 $13,851.00
Michael Massie 35.90 165.00 $5,923.50
Richard E. Coleson 26.20 530.00 $13,886.00
Richard E. Coleson 0.10 0.00 $0.00
Exhibit 5
Cawthorn Invoice May 26, 2022
JAMES BOPP, JR. THE BOPP LAW FIRM, PC

[email protected]
ATTORNEYS AT LAW

www.bopplaw.com
INVOICE
May 26, 2022
Madison Cawthorn
Thomas Datwyler
PO Box 183
Hudson, WI 54016
In Reference To:Cawthorn vs. NCSBE
Hrs/Rate Amount
4/1/2022 MM Review 2nd Emergency Motion to Stay 0.20 33.00

165.00/hr
MM Review Order Denying Intervention 0.70 115.50

165.00/hr
MM Review 2nd Emergency Motion to Stay 0.20 33.00

165.00/hr
Hrs/Rate Amount
4/1/2022 MM Phone conference with James Bopp, Jr. 0.10 16.50

regarding Response to 2nd Emergency Motion 165.00/hr
to Stay
MM Review 1st Emergency Motion to Stay and 1.40 231.00

Response to Emergency Motion to Stay 165.00/hr
MM Review Defendant's Response to Renewed 0.80 132.00

Motion to Intervene and Amicus Brief 165.00/hr
MM Review case law cited in 2nd Emergency 1.00 165.00

Motion to Stay 165.00/hr
MM Review 4th Circuit Local Rules 0.30 49.50

165.00/hr
MM Review 4th Circuit Local Rules 0.20 33.00

165.00/hr
MM Draft outline of Response to 2nd Emergency 1.10 181.50

MM Review Case law cited in Order Denying 1.30 214.50

Intervention 165.00/hr
MM Review Case law cited in Order Denying 0.70 115.50

Intervention 165.00/hr
JB Phone conference with Michael Massie 0.10 63.00

to Stay
4/4/2022 MM Draft Response to 2nd Emergency Motion to 7.30 1,204.50

Stay 165.00/hr
MM Review edits of Response to 2nd Emergency 0.30 49.50

Hrs/Rate Amount
4/4/2022 JB E-mail exchange with opposing counsel 0.30 189.00

regarding Motion to Expedite 630.00/hr
JB Review 4th Circuit Order regarding Response 0.30 189.00

630.00/hr
JB Revise draft Response to 2nd Motion to Stay 0.90 567.00

630.00/hr
4/5/2022 MM Phone conference with Melena Siebert 0.10 16.50

to Stay
MM Review edits from James Bopp, Jr. in Response 0.20 33.00

to 2nd Emergency Motion to Stay 165.00/hr
MM Make edits from James Bopp, Jr., finalize 2.10 346.50

documents and exhibits for filing 165.00/hr

to Stay

regarding response to motion to intervene 270.00/hr
MS Review, edit Response to Renewed Motion to 0.70 189.00

Stay, file same 270.00/hr
MS Review Motion to Accelerate, outline response 1.20 324.00

270.00/hr
JB Review draft of opposition to 2nd Stay Request 0.50 315.00

630.00/hr

regarding response to motion to intervene 165.00/hr
Hrs/Rate Amount
4/6/2022 MS Draft Response to Motion to Accelerate 2.00 540.00
270.00/hr
JB Revise opposition to Motion to Expedite 0.60 378.00

630.00/hr
4/7/2022 JB Review 4th Circuit order regarding expedited 0.30 189.00

appeal; phone conference with Melena Siebert 630.00/hr
JB Phone conference with opposing counsel 0.70 441.00

regarding attorney fee petition; phone 630.00/hr
conference with Melena Siebert

regarding settlement offer 270.00/hr

settlement offer 270.00/hr
JB Review 4th Circuit order regarding expedited 0.30 189.00

appeal 630.00/hr

regarding expedited appeal 630.00/hr
regarding NCSBE settlement offer; contact 630.00/hr
client and respond to NCSBE
4/10/2022 JB Review draft agreement regarding NCSBE 0.50 315.00

appeal; phone conference with Melena Siebert 630.00/hr
regarding response

4/11/2022 JB Review 4th Circuit Order 0.30 189.00
630.00/hr
Hrs/Rate Amount
4/11/2022 JB Review email from Cawthorn 0.30 189.00

630.00/hr
4/12/2022 MS Review docket for Joint Appendix inclusion 0.50 135.00

270.00/hr

appeal 270.00/hr
4/13/2022 JPG E-mail exchange with Melena Siebert, James 0.30 142.50
Bopp, Jr. regarding withdrawing fee petition 475.00/hr
MS Review Joint Appendix, email exchanges with 0.20 NO CHARGE

opposing counsel regarding same 270.00/hr
JB E-mail exchange regarding attorney fees 0.30 189.00

630.00/hr
MS E-mail exchange with Jeffrey P. Gallant and 0.30 81.00

James Bopp, Jr. regarding withdrawing fee 270.00/hr
petition
JB E-mail exchange with Jeffrey P. Gallant and 0.30 189.00

Melena Siebert regarding withdrawing fee 630.00/hr
petition
4/14/2022 JB Review Amicus Curiae Brief 0.70 441.00

630.00/hr
JB Review brief by Intervenor 1.50 945.00

630.00/hr
4/15/2022 JB Review Opposition 4th Circuit brief 1.80 1,134.00

630.00/hr
4/18/2022 MS Review Appellant's brief, phone conference 1.20 324.00

with James Bopp, Jr. regarding appellee's brief 270.00/hr
Hrs/Rate Amount
4/18/2022 MS E-mail to Michael Massie regarding appellee 0.60 162.00

brief 270.00/hr
MS Review of appellee brief, email exchange with 1.00 270.00

James Bopp, Jr. regarding same 270.00/hr
MM Review Appellant's Brief 0.80 132.00

165.00/hr
MM Review local rules 0.80 132,00

165,00/hr
MM Review documents sent by Melena Siebert, 1.10 181.50

make notes 165.00/hr
regarding Response to Appellant's Brief 165.00/hr
MM Review Appellant's Brief, make notes 1.60 264,00

165.00/hr
MM Draft Outline of Response to Appellant's Brief 0.70 115.50

165,00/hr

regarding Appellee brief; review Melena 630.00/hr
Siebert email regarding brief
JB Phone conference with Melena Siebert 0.30 189,00

regarding filing oral argument certificate; 630.00/hr
review certificate
JB Review amicus brief by Constitutional 0.80 504.00

Accountability Center 630.00/hr
JB Phone conference with associates regarding 0.80 504.00

preparation of appellee brief 630.00/hr
Hrs/Rate Amount
4/18/2022 MS Phone conference with Michael Massie 0.10 27.00

regarding Response to Appellant's Brief 270.00/hr

regarding filing oral argument certificate 270.00/hr
4/19/2022 MM Review Appellant's Brief, draft outline for 0.60 99.00

appellee's brief 165.00/hr
4/20/2022 MM Review Appellant's Brief 0.40 66.00

165.00/hr
MM Review outline and notes on Appellant's Brief 0.30 49.50

165.00/hr
4/21/2022 MM Draft Appellee's Brief 8.00 1,320.00
165.00/hr
JB Review amicus brief 0.90 567.00

630.00/hr
4/22/2022 MM Draft Appellee's Brief 6.20 1,023.00

165.00/hr
ES E-mail with counsel press for quote for printing 0.30 49.50
the brief 165.00/hr
regarding brief 630.00/hr
JB Revise appellee's brief 2.50 1,575.00

630.00/hr

regarding brief 270.00/hr
4/24/2022 MS Edit Appellee Brief 4.80 1,296.00
270.001hr
Hrs/Rate Amount
4/24/2022 JB Revise appellee's brief 6.20 3,906.00

630.00/hr
4/25/2022 MS Draft private right of action module, send to 0.80 216.00

James Bopp, Jr. for inclusion in appellee brief 270.00/hr

regarding revisions to appellee brief 270.00/hr
MS Edit appellee brief, file 4.30 1,161.00

270.00/hr
JB Revise appellee's brief; numerous phone 4.20 2,646.00

conferences with Melena Siebert regarding 630.00/hr
issues; review module; include in brief
JB Review State Defense amicus brief 0.60 378.00

630.00/hr
JB Revise revised appellee brief 2.50 1,575.00

630.00/hr
4/29/2022 MS Review letter from NCSBE regarding appellee 1.70 459.00

brief, draft response to same, send to James 270.00/hr
Bopp, Jr. for review
JB Consent to amicus brief 0.30 189.00

630.00/hr
JB Review Reply brief 1.50 945.00

630.00/hr
JB Review letter from NC regarding our brief; 0.80 504.00

regarding Response; review draft Response
Letter; approve
JB Review State Defense Amicus Brief 0.60 378.00

630.00/hr
Hrs/Rate Amount

regarding Response 270.00/hr
4/30/2022 JB Preparation for oral argument 1.10 693.00

630.00/hr
JB Review text message 0.30 189.00

630.00/hr

Additional charges:
Qty/Price

research--research cited cases for response to motion to $3.00
accelerate

research--research SMJ regarding intervention $3.00

research--research on Rules of Evidence in NC; $3.00
NCAPA
Total costs $42.00


Attorney Summary
Name Hrs/Rate Rate __A
=-==
m=o-=
un=t
Emma Shirley 0.30 165.00 $49.50
James Bopp, Jr. 34.80 630.00 $21,924.00
Melena Siebert 20.90 270.00 $5,643.00
Michael Massie 38.80 165.00 $6,402.00
Exhibit 6
Cawthorn Invoice July 1, 2022
JAME S B O PP, JR ,
[email protected]
ATTORNEYS AT LAW

www.bopplaw.com
INVOICE
July 1, 2022
Madison Cawthorn
Thomas Datwyler
PO Box 183
Hudson, WI 54016
Hrs/Rate Amount
5/1/2022 JB Preparation for hearing; review case 2.30 1,449.00
630.00/hr
5/2/2022 MS Draft motion to file corrected appellee's brief, 2.00 540.00

email exchanges with opposing counsel 270.00/hr
regarding same, edit appellee brief in
compliance with motion, phone conference with
James Bopp, Jr. regarding same
JB Preparation for oral argument 1.80 1,134.00

630.00/hr
Hrs/Rate Amount
5/2/2022 JB Review email exchange regarding filing 0.30 189.00

corrected brief 630.00/hr

regarding corrected brief 630.00/hr
JB Preparation for oral argument; travel to 5.00 3,150.00

Richmond, VA 630.00/hr
5/3/2022 ES Listen to James Bopp, Jr.'s oral argument before 2.20 NO CHARGE
the Court of Appeals, make notes; research 165.00/hr
judges
JB Preparation for oral argument; phone 3.10 1,953.00

JB Attend Oral Argument 2.50 1,575.00
630.00/hr
JB Phone calls with numerous press 1.50 945.00
630.00/hr
regarding preparation for oral argument 270.00/hr
5/4/2022 JB Travel to Indianapolis, Indiana 4.50 2,835.00
630.00/hr
JPG Conference with Melena Siebert regarding 0.10 47.50
Cawthorn hearing
475.00/hr
MS Conference with Jeffrey P. Gallant regarding 0.10 27.00
Cawthorn hearing
270.00/hr
5/9/2022 MS Phone conference with client regarding videos 0.20 54.00
released
270.00/hr
5/10/2022 MS Phone conference with client, James Bopp, Jr. 0.20 54.00
regarding videos, research needed 270.00/hr
Hrs/Rate Amount
5/10/2022 JB Phone conference with client, Melena Siebert 0.20 126.00

regarding videos, research needed 630.00/hr
5/12/2022 MS E-mail exchange with Emma Shirley regarding 0.20 54.00

research needed on videos posted 270.00/hr
ES E-mail exchange with Melena Siebert regarding 0.20 33.00

research needed on videos posted 165.00/hr
ES Research NC revenge statutes 0.30 49.50

165.00/hr

regarding appeal motion; review email exchange 630.00/hr

regarding appeal motion 270.00/hr
5/19/2022 MS E-mail exchanges with client, opposing counsel 0.50 135.00

regarding filing suggestion of mootness 270.00/hr
JB Review email exchange regarding suggestion of 0.40 252.00

mootness 630.00/hr
JPG Phone conference, email exchange with Melena 1.00 475.00

Siebert regarding suggestion of mootness; 475.00/hr
review BLF files and send exemplars to Melena
Siebert
MS Phone conference, email exchange with Jeffrey 0.20 54.00

P. Gallant regarding suggestion of mootness 270.00/hr
5/20/2022 MS Draft, file suggestion of mootness 1.00 270.00

270.00/hr
5/24/2022 MS Phone conference with James Bopp, Jr., local 0.30 81.00
counsel regarding 4th Circuit Opinion 270.00/hr
Hrs/Rate Amount
5/24/2022 MS Review 4th Circuit Opinion 1.00 270.00

270.00/hr
JB Review 4th Circuit decision 1.20 756.00

630.001hr
5/25/2022 JB Phone conference with Melena Siebert, local 0.30 189.00

counsel and client representatives 630.00/hr
MS Phone conference with James Bopp, Jr., local 0.30 81.00

counsel and client 270.00/hr

Additional charges:
Qty/Price
5/2/2022 Travel expense for James Bopp, Jr. from May 02--04, 1 1,205.10
2022 to attend 4th Circuit Court Argument in $1,205.10
Richmond, VA
5/10/2022 Cost advanced for paper copies of brief and appendices 1 1,373.00
to 4th Circuit Court of Appeals--paid online on $1,373.00
05-10-22--payable to Counsel Press--Invoice #
09136088--MC
Total costs
$2,578.10
Total amount of this bill

$19,869.10
Previous balance
$173,184.75
Balance due
$193,053.85
Attorney Summary
------''-===
Emma Shirley 0.50 165.00 $82.50
Emma Shirley 2.20 0.00 $0.00
James Bopp, Jr. 23.70 630.00 $14,931.00
Melena Siebert 6.50 270.00 $1,755.00
Exhibit 7
Cawthorn Invoice July 28, 2022

[email protected]
ATTORNEYS AT LAW

l South Sixth Street
www.bopplaw.com
INVOICE
July 28, 2022
Madison Cawthorn
Thomas Datwyler
PO Box 183
Hudson, WI 54016
Hrs/Rate Amount
6/15/2022 JB Review court order 0.30 189.00

630.00/hr
6/16/2022 MS Review order to show cause on mootness, email 0.20 54.00

to client regarding same 270.00/hr
JPG Notice of Electronic Filing 0.10 NO CHARGE

475.00/hr
6/28/2022 MS E-mail client regarding filing on mootness 0.10 NO CHARGE

270.00/hr
Hrs/Rate Amount
6/30/2022 MS E-mail exchange regarding stipulation of 0.50 NO CHARGE

dismissal - file same 270.00/hr
For professional services rendered 1.20 $243.00

Attorney Summary
----''---"===
James Bopp, Jr. 0.30 630.00 $189.00
Melena Siebert 0.20 270.00 $54.00
Exhibit 8
Cawthorn Invoice Aug. 24, 2022

[email protected]
ATTORNEYS AT LAW

Telephone 812/232-2434 Facsimile 812/23 5-3685
www.bopplaw.com
INVOICE
August 24, 2022
Madison Cawthorn
Thomas Datwyler
PO Box 183
Hudson, WI 54016
In Reference To:Cawthom vs. NCSBE
Hrs/Rate Amount
7/1/2022 MS E-mail to client regarding grant of dismissal 0.20 NO CHARGE

270.00/hr
For professional services rendered 0.20 $0.00


Attorney Summary
Name Hrs/Rate Rate --~~~
Amount
Exhibit 9
Cawthorn Invoices Sept. - Nov., 2022

[email protected]
ATTORNEYS AT LAW

www.bopplaw.com
INVOICE
September 26, 2022
Madison Cawthorn
Thomas Datwyler
PO Box 183
Hudson, WI 54016
Amount

JAMES BOPP, JR.

[email protected]
ATTORNEYS AT LAW

www.bopplaw.com
INVOICE
October 19, 2022
Madison Cawthorn
Thomas Datwyler
PO Box 183
Hudson, WI 54016
Amount


[email protected]
ATTORNEYS AT LAW

www.bopplaw.com
INVOICE
November 22, 2022
Madison Cawthorn
Thomas Datwyler
PO Box 183
Hudson, WI 54016
Amount

Civil Lawsuit Against Madison Cawthorn From The Bopp Law Firm

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Civil Lawsuit Against Madison Cawthorn From The Bopp Law Firm

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Case 2:22-cv-00554-JRS-MG Document 9 Filed 12/07/22 Page 1 of 11 PageID #: 119

UNITED STATES DISTRICT COURT

The Bopp Law Firm, PC, an Indiana professional

Mr. Madison Cawthorn., an individual,

Amended Complaint for Compensatory Damages

account stated claims.

Jurisdiction and Venue

matter in controversy exceeds $75,000 and is between citizens of different states.

Haute, Indiana. Therefore, pursuant to 28 U.S.C. § 1332(c)(1), BLF is a citizen of Indiana.

Am. Compl. for

and property tax bills are sent to this address.

voter in Hendersonville, North Carolina. See screenshot of NCSBE Voter Search:

Am. Compl. for

matter in controversy exceeds $75,000 and is between citizens of different states.

law and Rule 54 of the Federal Rules of Civil Procedure.

Agreement for Legal Services (“Agreement”) he entered into with BLF.

12. Plaintiff BLF is an Indiana professional corporation headquartered at The National

Building, 1 South Sixth St., Terre Haute, Indiana 47807.

Am. Compl. for

petitions for attorneys’ fees allowed under federal law.

16. The fully executed Agreement is attached to this Complaint as Exhibit 1.

Agreement on his own behalf.

and payable within 30 days of receipt by Mr. Cawthorn. Id. at 1.

accounts until paid. Id.

Am. Compl. for

BLF is necessary to collect any unpaid amounts due. Id.

located in Indiana could resolve the dispute. Id. at 2.

BLF Performance and Mr. Cawthorn’s Breach

invoices to Mr. Cawthorn on a monthly basis.

challenge before the North Carolina State Election Board (“Board”).

qualifications was brought.

opposed—twice—the intervention by the challengers, protected his interests in state redistricting

and advised the campaign in successfully navigating the change in districts.

Am. Compl. for

pay those fees under the terms of the Agreement.

34. BLF re-alleges and incorporates by reference all previous allegations.

Am. Compl. for

terms of the Agreement.

interest due, he breached the Agreement.

collecting the unpaid amounts, as a direct result of Mr. Cawthorn’s breach.

Am. Compl. for

43. BLF re-alleges and incorporates by reference all previous allegations.

Trancik, 953 N.E.2d 1087, 1091 (Ind. Ct. App. 2011).

undisputed, what constitutes a reasonable time to object to a statement of account is a question of

Cawthorn went unpaid and are currently unpaid. Invoices, Exs. 2 - 9.

Am. Compl. for

invoices, Exs. 2 - 9, or to the correctness of the account balance.

$193,296.85 on the account stated claim.

Prayer for Relief

WHEREFORE, Plaintiff prays for the relief set forth below:

2. Award pre-judgment interest on any compensatory damage awarded to BLF against

5. Grant any other relief this Court deems appropriate.

Am. Compl. for

Date: December 7, 2022 Respectfully submitted,

Am. Compl. for

service of summons in compliance with Federal Rule of Civil Procedure 4 upon:

Mr. Madison Cawthorn

/s/ James Bopp, Jr.

Am. Compl. for

THE NATIONAL BUTI..DING

In Reference To:Adm_inistrative Challenge to Candidacy and Suit vs. NCSBE

1/10/2022 MS Phone conference with with Blake Harp 0.20 54.00