EFTA00799102
EFTA00799106 DataSet-9
EFTA00799145

EFTA00799106.pdf

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Deutsche Bank Wealth Management Wire Confirmation The wire transfer request below has been transmitted successfully. Transmitted: 05/03/2018 12:46:04 PM (ET) Transmitted By: BELLAKLEIN Effective Confirmation Approval Account Template Name Recipient Name Amount Currency Date Number Status Jeffrey Epstein - JEE to Link and Link and 142.908.11 USD 05/03/2018 1228598073 1 of I received NOW - '9691 Rockenbach PA Rockenbach, PA. EFTA00799106 Link & Rockenbach, PA 1555 Palm Beach Lakes Blvd. Suite 301 West Palm Beach, FL 33401 561-727-3600 Tax ID No. 82-3083928 May 3, 2018 Jeffrey Epstein 0002 6100 Red Hook Quarter, B3 St. Thomas, USV 00802 Statement Matter Running Date Bill Number/Description Bill Amount Paid Amount Balance 0001 - Bradley Edwards 10/24/17 1 49,985.00 49,985.00 10/24/17 Earned Non-Refundable Fee 49,985.00 0.00 11/06/17 32937 / Initial Bill from Time Slips 194,971.50 194,971.50 11/13/17 Payment Inv. No. 32937 from Time Slips 194,971.50 0.00 12/11/17 2 / Initial Bill from Time Slips Bill # 32942 257,198.13 257,198.13 12/11/17 Payment In. No. 32942 from Time Slips 257,198.13 0.00 12/31/17 9 219,076.50 219,076.50 01/09/18 WT / Wire Transfer 150,000.00 69,076.50 01/31/18 Applied to 9. 69,076.50 0.00 02/01/18 84 279,560.88 279,560.88 02/27/18 Wire Transfer Invoice #84 279,560.88 0.00 03/05/18 226 226,888.08 226,688.08 04/03/18 Applied to 226. 226,688.08 0.00 04/06/18 396 392,908.11 392,908.11 04/24/18 180424129069 / Applied to 396. 250,000.00 142,908.11 Matter Balance Due Total Balance Due So EFTA00799107 LINK & ta ROCKENBACH, ■. CIVIL TRIAL & APPELLATE LAW 1555 Palm Beach Lakes Blvd., Suite 301 West Palm Beach, Florida 33401 T 561.727.3600 F 561.727.3801 Wire Transfer Instructions Wire Transfer to: Wells Fargo Bank, N.A. Routing No. / ABA No.: 121000248 Address: 420 Montgomery San Francisco, CA 94104 Beneficiary Account No.: Beneficiary Name: Link & Rockenbach, P.A. Address: 1555 Palm Beach lakes, Blvd. Suite 301 West Palm Beach, FL 33401 Additional Information: Operating Account EFTA00799108 From: Darren IndykS1 Subject: Fwd: Balance Due Date: May 3, 2018 1 To: Richard Kahn Cc: Darren Indyke Jeffrey said ok to pay this balance on the April Invoice for March time. Do you have the invoice or shall I send again. DARREN K. INDYKE DARREN K. INDYKE, PLLC 575 Lexington Avenue, 4th Floor New York New York 10 The information contained in this communication is confidential, may be attorney-client privileged, and is intended only for the use of the addressee. It is the property of Darren K. Indyke, PLLC. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail, and destroy this communication and all copies thereof, including all attachments. Copyright of Darren K. Indyke, PLLC - 2018 Darren K. Indyke, PLLC — All rights reserved. Begin forwarded message: From: "Paul V. DeVito" ‹ > Subject: Balance Due Date: May 3, 2018 : : T To: Darren Indyke < > Good morning Mr. Indyke. I have attached a copy of Mr. Epstein's Statement showing a balance due of $142,908.11. I have also attached wire transfer instructions for your reference. Please let me know if you need any additional information. Thank you very much for your help. Paul DeVito L IR LINK& ROCKENBACH, PA CIVIL TRIAL & APPELLATE LAW Bookkeeper Billing Coordinator LINK & ROCKENBACH, PA 1555 Palm Beach Lakes Blvd., Suite 301 West Palm Beach.FL 1 EFTA00799109 LINK& 1555 Palm Beach Lakes Blvd., Suite 301 ILIR ROCKENBACH 9 PA CIVIL TRIAL & APPELLATE LAW West Palm Beach, FL 33401 TEL (561) 727-3600 I FAX (561) 727-3601 April 10, 2018 Via Email leevacationegmaitcom Jeffrey Epstein 6100 Red Hook Quarter, 83 St. Thomas, USVI 00802 Re: Jeffrey Epstein v. Bradley J. Edwards File No.: 2.0001 Dear Jeffrey: Attached please find our firm's billing statement for services rendered through March 31, 2018. I have carefully reviewed this statement and as a courtesy to you, I reduced the bill in the amount of $12,190.00 ($100.00 x 121.9 hours). The line items beginning with "No Charge" reflect an additional reduction in the amount of $20,393.50 making the total reduction $32,583.50. Please do not hesitate to call me if you have any questions regarding this bill. Thank you. Very truly yours, Scott J. Link SJL/pvd Attachment cc: Darren Indyke w/attachment EFTA00799110 irt LINK & ROCKENBACH, P.A. CIVIL TRIAL & APPELLATE LAW 1555 Palm Beach Lakes Blvd., Suite 301 Went Palm Beach, Florida 33401 T 561.7273600 F 561.727.3601 Wire Transfer Instructions Wire Transfer to: Wells Fargo Bank, N.A. Routing No. / ABA No.: 121000248 Address: 420 Montgomery San Francisco, CA 94104 Beneficiary Account No.: Beneficiary Name: Link & Rockenbach, P.A. Address: 1555 Palm Beach lakes, Blvd. Suite 301 West Palm Beach, FL 33401 Additional Information: Operating Account EFTA00799111 Link & Rockenbach, PA 1555 Palm Beach Lakes Blvd. Suite 301 West Palm Beach, FL 33401 561-727-3600 Tax ID No. 82-3083928 Jeffrey Epstein April 6, 2018 6100 Red Hook Quarter, B3 Invoice # 396 St. Thomas, USV 00802 CLIENT: 0002 - Jeffrey Epstein Re: 0001 Bradley Edwards Date Services Hours Amount 03/01/18 RJG Attend team meeting re trial plan 1.00 395.00 03/01/18 RJG Research assertion of constitutional privileges 2.10 829.50 against self-incrimination in civil cases, waiver of same, assertion of privilege in discovery, in preparation for drafting Response to Edwards' Motion to Compel Response to Request for Admissions 03/01/18 RJG Continue drafting/revising Response in Opposition to 2.10 829.50 B. Edwards' Motion to Compel Response to Request for Admissions 03/01/18 RJG Begin updating research on malicious 1.90 750.50 prosecution/elements and recent case law in preparation for trial 03/01/18 RJG Review/analyze B. Edwards' Motion for Separate 0.80 316.00 Trials or, in the Alternative to Adjust the Order of Proof, in preparation for drafting response 03/01/18 RJG Begin researching bifurcation of trial/eleventh-hour 0.60 237.00 request, in preparation for drafting response to B. Edwards' Motion for Separate Trials 03/01/18 AMP [No Charge] Update hearing transcripts binder and 2.00 0.00 prepare updated index for same EFTA00799112 Client Ref: 0002 - 0001 April 6, 2018 Invoice # 396 Page 2 Date Services Hours Amount 03/01/18 SJL Work on issues relating to disclosure of key e-mails; 12.80 9,600.00 work on Notice/Appendix of same; work on Motion for Court's Permission to Alter Trial Evidence; multiple telephone conferences and communications with D. Indyke and J. Epstein re same; follow up on hearing schedule; trial team meeting with J. Goldberger, M. Goldberger, J. Caldwell, T. Campbell, R. Glasser and K. Rockenbach re trial work, hearing preparations and strategies; work on objections to B. Edwards' deposition designations 03/01/18 TLC Continue working on itemizing all key emails and 14.80 3,330.00 public records located on witnesses on Clerk's Trial Exhibit List; work on culling out key emails to disclose to Court; work on trial exhibits; work on Appendix of key e-mails; work on confidentiality issues; follow up with opposing counsel re hearing and production of audio; work on chronology; begin reviewing new public records 03/01/18 KBR Prepare objections to B. Edwards' deposition 8.20 6,150.00 designations and consider counter-designations; attend trial team strategy meeting; prepare/revise motion to redact names and alter trial exhibits; work on Response to B. Edwards' Motion to Compel Response to Request for Admissions re sex offender registry's authenticity and accuracy; analyze B. Edwards' proposed Juror Questionnaire and email J. Scarola for Word version in order to edit; work on same 03/01/18 PVD [No Charge] Work on preparation of Trial Exhibits 7.50 0.00 03/02/18 RJG Continue researching bifurcation of trial, 11th-hour 3.20 1,264.00 request, bifurcation as waste of judicial resources, bifurcation where claim and counterclaim are interrelated and waiver of bifurcation 03/02/18 RJG Research pre-trial stipulations as binding on parties 2.90 1,145.50 and the court and strictly enforced; stipulation to consolidated trial; order and scope of proceedings/whether counterclaim can proceed first 03/02/18 RJG Begin drafting Response to B. Edwards' Motion for 3.30 1,303.50 Separate Trials or, in the Alternative to Adjust Order of Proof EFTA00799113 Client Ref: 0002 - 0001 April 6, 2018 Invoice # 396 Page 3 Date Services Hours Amount 03/02/18 KBR Work on trial preparations; work on trial exhibits; 5.50 4,125.00 work on Motions for Permission to Alter Trial Evidence and Rule of Judicial Administration 03/02/18 TLC Work on summary of all litigation, arrests and sheriff 14.50 3,262.50 reports for S. Rivera, T. Miller and C. Wild to include In Motion to Alter Evidence; work on same; work on Notice of Filing Appendix in Support of Response in Opposition to B. Edwards' Second Supplement to Motion in Limine Addressing Scope of Admissible Evidence; work on hearing needs; follow up on V. Roberts' audio tape; prepare Notice of Cancellation of Hearing; work on Clerk's Trial Exhibit List to identify each item individually 03/02/18 SJL Continue working on Notice of Filing Appendix in 12.80 9,600.00 Support of Response in Opposition to B. Edwards' Second Supplement to Motion in Limine Addressing Scope of Admissible Evidence; address confidentiality concerns; multiple communications with D. Indyke and J. Epstein re same; work on two Motions to Alter Evidence; communications with potential jury selection consultants; work on opening statement; work on trial strategies; follow up on audio tape of V. Roberts 03/02/18 PVD [No Charge] Work on preparation of Trial Exhibits 7.50 0.00 03/03/18 SJL Work on Response to Motion to B. Edwards' Compel 7.30 5,475.00 re Request for Admissions; strategize re default against S. Rothstein and options to proceed with trial or seek to strike trial setting; work on preparations for special set hearings; work on trial preparations EFTA00799114 Client Ref: 0002 - 0001 April 6, 2018 Invoice # 396 Page 4 Date Services Hours Amount 03/03/18 TLC Work on preparations for hearing on all outstanding 10.00 2,250.00 motions: (1) Epstein's Motion for Case Management Conference, (2) Edwards' Motion for Separate Trials; (3) Edwards' Second Supplement to Motion in Limine Addressing Scope of Admissible Evidence, (4) Edwards' Motion in Limine to Limit Introduction of Evidence Alleged to Support Epstein's Claims Against Edwards; (5) Epstein's Motions for Permission to Alter Evidence; (6) Epstein's Motion for Protective Order and in Limine of Unrelated Settlements; (7) Edwards' Second Motion to Lift Confidentiality; (8) Edwards' Motion for Adverse Inference; (9) Edwards' Motion in Limine Scope of Admissible Evidence; (10) Epstein's Motion to Strike Damages Expert; (11) Edwards' Motion in Limine Addressing the Admissibility of Edwards' Exhibit 132; (12) Epstein's Motion in Limine re Sex Offender Registry; (13) Epstein's Motion in Limine on Edwards' Newly Disclosed Exhibits; (14) Epstein's Request for Judicial Notice; and (15) Objections to Deposition Designations; assemble hearing notebooks and materials for each; pull authorities and prepare indices where needed; work on sequence list of motions; prepare Notice of Hearing and letter to judge; work on Response to Motion to Compel re Request for Admissions; work on assembling unredacted set of evidence and serve same 03/03/18 RJG Review/Analyze B. Edwards' Supplement to Motion 2.90 1,145.50 for Separate Trials or, in the Alternative to Adjust Order of Proof, and case law cited therein; revise Response in Opposition to Motion for Separate Trials, etc., to address Supplement; revise response per partners' suggested changes 03/03/18 RJG Legal research when case is "at issue" and propriety 1.60 632.00 of clerk's default v. judge's default; revise Response in Opposition to B. Edwards' Motion for Separate Trials to Include "at issue" argument 03/03/18 KBR Work on preparations for trial; work on Motion to 7.30 5,475.00 Remove Case from Trial Docket in compliance with Florida Rule of Civil Procedure 1.440; work on Response to B. Edwards' Motion to Severe; conduct legal research on appellate vehicle should the Court grant B. Edwards' Motion to Severe EFTA00799115 Client Ref: 0002 - 0001 April 6, 2018 Invoice # 396 Page 5 Date Services Hours Amount 03/04/18 TLC Continue working on itemized Clerk's Trial Exhibit 9.70 2,182.50 List; work on Objections to Deposition Designations; prepare Motion for Default and Default Judgment against S. Rothstein; work on timeline for Response to Motion to Severe; work on issues relating to production of disc; work on marking trial exhibits 03/04/18 KBR Continue working on trial preparations; continue 9.00 6,750.00 working on Response to B. Edwards' Motion to Severe and Motion to Strike from Trial Docket; conduct further legal research on appellate options 03/04/18 PVD [No Charge] Work on preparation of Trial Exhibits 10.50 0.00 03/05/18 RJG Revise Response in Opposition to Edwards' Motion 1.00 395.00 for Separate Trials per partners' suggested changes; insert/address timeline 03/05/18 AMP [No Charge] Prepare binder re J. Epstein's Notice of 1.00 0.00 Filing of Redacted Appendix in Support of Response in Opposition to B. Edwards' Second Supplement to Motion in Limine Addressing Scope of Admissible Evidence 03/05/18 AMP [No Charge] Prepare packet regarding J. Epstein's 0.40 0.00 Motion in Limine as to Sex Offender Registry Information 03/05/18 RJG Research mandamus as proper vehicle to enforce 2.50 987.50 time restrictions for setting of a trial; requirements for mandamus relief; begin drafting proposed emergency relief Petition for Writ of Mandamus 03/05/18 TMB (No Charge] Finalize letter to T. Chinaris re packet of 0.10 0.00 exhibits 03/05/18 RJG Review/analyze B. Edwards' Motion in Limine to Limit 2.50 987.50 Introduction of Evidence Alleged to Support J. Epstein's Claims Against B. Edwards and accompanying J. Epstein deposition. excerpts; conduct preliminary research in preparation for drafting response EFTA00799116 Client Ref: 0002 - 0001 April 6, 2018 Invoice # 396 Page 6 Date Services Hours Amount 03/05/18 TLC Work on Clerk's Trial Exhibit List; finalize and file 13.50 3,037.50 same; work on organizing and marking trial exhibits; work on Motion for Default; work on J. Epstein's Motion to Remove Case from Trial Docket in Order to Comply With the Mandate Set Forth in Rule 1.440; work on Response to B. Edwards' Motion for Separate Trials; work on Motion for Court to Declare Relevance and Non-Privileged Nature of Documents and Request for Additional Limited Discovery, Evidentiary and Appointment of Special Master; work on assembling authorities and hearing folder for our Motion to Remove Case from Trial Docket; telephone conference with trial support; follow up with D. Vitale re proposed Order from hearing on our Motion for Protective Order re settlements; follow up with J. Scarola's assistant re unilateral setting of hearings and request for cancellation; work on hearing folder on our Response to B. Edwards' Motion for Separate Trials; assemble authorities for same; prepare Notice of no objection to sealing records until Court makes determination 03/05/18 SJL Multiple communications with J. Scarola, P. Cassell, 11.20 8,400.00 D. Indyke and J. Epstein re production of emails and treatment / alleged improperly obtaining privilege documents; work on Motion to Strike from Trial Docket; work on Response to B. Edwards' Motion to Severe; work on Motion for Court to Declare Relevance and Non-Privileged Nature of Documents, etc.; work on preparations for special set hearing and addressing outstanding Order on settlement issues; work on proposed sequence of Motions 03/06/18 TMB [No Charge] Draft Petition for Writ of Certiorari shell 0.20 0.00 03/06/18 TMB (No Charge] Work on Appendix to Petition for Writ of 0.10 0.00 Certiorari shell 03/06/18 TMB [No Charge] Work on Request for Emergency 0.20 0.00 Treatment per Fourth District Court of Appeal's Administrative Order 03/06/18 TMB [No Charge) Work on Affidavit for T. Chinaris 0.20 0.00 EFTA00799117 Client Ref: 0002 - 0001 April 6, 2018 Invoice # 396 Page 7 Date Services Hours Amount 03/06/18 RJG Continue drafting/revising proposed Emergency 5.30 2,093.50 Petition for Writ of Mandamus in preparation for trial court denying Motion to Strike Case from Docket 03/06/18 RJG Revise proposed Emergency Petition for Writ of 1.90 750.50 Mandamus per partners' suggested changes; verify all citations 03/06/18 RJG Review pleadings/timeline for statement of facts 1.30 513.50 section of proposed Emergency Petition for Writ of Mandamus 03/06/18 TLC Work on analysis of Farmer Jaffe Privilege Log; work 14.00 3,150.00 on Notice of No Objection to Sealing Records; work on Response to B. Edwards' Motion to Strike J. Epstein's Untimely Supplemental Exhibits; work on trial exhibits; prepare letter to judge with additional hearing submissions; work on Notice of Hearing 03/06/18 SJL Work on issues surrounding production of 27,000 13.00 9,750.00 page email disc; multiple communications with P. Cassell; follow up with client re position; work on Response to Motion to Strike J. Epstein's Untimely Supplemental Exhibits; work on Petition for Writ of Mandamus 03/06/18 KBR Work on Petition for Writ of Mandamus; work on 10.00 7,500.00 Affidavit of T. Chinaris; communica tions with T. Chinaris re same; work on trial preparations; work on preparations for special set hearing on all pending Motions; work on Response to Motion to Strike J. Epstein's Untimely Supplemental Exhibits 03/06/18 PVD [No Charge] Work on procuring documents 7.50 0.00 considered to be privileged materials at issue in B. Edwards' Motion to Strike J. Epstein's Untimely Supplemental Exhibits 03/07/18 RJG Review/analyze/research B. Edwards' Motion in 2.10 829.50 Limine to Limit the Introduction of Evidence Alleged to Support J. Epstein's Claims Against B. Edwards;draftlrevise Response to same 03/07/18 TMB [No Charge] Review Fourth District Court of Appeal's 0.20 0.00 emergency treatment procedures in preparation for Petition Mandamus EFTA00799118 Client Ref: 0002 - 0001 April 6, 2018 Invoice # 396 Page 8 Date Services Hours Amount 03/07/18 TMB [No Charge] Review clerk's records regarding 0.30 0.00 hearing on multiple motions on 3/8/18 and Order Resetting Trial in preparation for Motion to Stay [No Charge] Review Motion to Stay case - in 0.30 0.00 03/07/18 TMB preparation for potential appeal 03/07/18 RJG Finalize pending responses for 3/8118 Special Set 6.90 2,725.50 Hearing; conference with partners re proposed Emergency Petition for Writ of Mandamus and other "emergency" filings to have in pipline; revise draft Mandamus Petition accordingly; review all case law citations in preparation for filing 03/07/18 TLC Work on trial exhibits; work on preparations for 14.50 3,262.50 special set hearing; follow up with trial support; work on Objections to Deposition Designations; work on updating trial binders; work on Response to B. Edwards' Motion to Strike Epstein's Supplemental Exhibits and to Strike All Exhibits and Any Reference to Documents Containing Privileged Materials Listed on B. Edwards' Privilege Log; work on Response in Opposition to B. Edwards' Motion in Limine to Limit the Introduction of Evidence Alleged to Support J. Epstein's Claims Against B. Edwards; prepare Affidavit of T. Campbell re chain of custody of disc; prepare Notices of Filing Affidavits of T. Campbell and T. Chinaris; work on schedule of motions to be heard; communications with D. Indyke; prepare letter and package to Judge Hafele re additional hearing submissions; prepare letter to J. Scarola re delivery of disc; carefully review redacted appendix to see if we missed redacting any alleged victims' names as alleged by P. Cassell EFTA00799119 Client Ref: 0002 - 0001 April 6, 2018 Invoice # 396 Page 9 Date Services Hours Amount 03/07/18 SJL Work on Response in Opposition to B. Edwards' 12.30 9,225.00 Motion in Limine to Limit the Introduction of Evidence Alleged to Support J. Epstein's Claims Against B. Edwards; work on Affidavit of T. Campbell re chain of custody of disc; communications with T. Chinaris re Affidavit; work on Response in Opposition to B. Edwards' Motion in Limine to Limit the Introduction of Evidence Alleged to Support J. Epstein's Claims Against B. Edwards; work on Emergency Motion for Writ of Mandamus; telephone conferences with P. Cassell; review Cassell's filings and follow up on issues raised by same; communications with P. Cassell and J. Scarola re production of disc; communications with D. Indyke and J. Epstein 03/07/18 KBR Work on preparation for 3/8/18 hearings on 20+ 6.00 4,500.00 Motions/issues 03/07/18 PVD [No Charge] Work on chronology of privileged 3.50 0.00 materials at issue 03/07/18 PVD [No Charge] Work on procuring transcript of hearing 1.00 0.00 on 8/3/12 03/07/18 PVD [No Charge] Work on analysis of documents 1.00 0.00 produced 03/08/18 TMB (No Charge] Work on Request for Emergency 0.20 0.00 Treatment pursuant to Fourth District Court of Appeal's instructions 03/08/18 TMB [No Charge] Prepare bookmark Appendix to Petition 0.40 0.00 for Writ of Mandamus 03/08/18 TMB [No Charge] Review and revise Appendix to Petition 0.20 0.00 for Writ of Mandamus 03/08/18 TMB [No Charge] Work on revisions to Appendix to 0.90 0.00 Emergency Petition for Writ of Mandamus and to Emergency Motion for Review of Order Denying Stay 03/08/18 TMB [No Charge] Work on Request for Emergency 0.20 0.00 Treatment EFTA00799120 Client Ref: 0002 - 0001 April 6, 2018 Invoice # 396 Page 10 Date Services Hours Amount 03/08/18 TMB (No Charge] Work on revisions to Index to 0.30 0.00 Emergency Petition for Writ of Mandamus and Emergency Motion for Review of Order Denying Stay 03/08/18 RJG Attend special set hearing before Judge Hafele re 3.00 1,185.00 pending motions 03/08/18 RJG Draft/revise Emergency Motion for Review of Order 5.10 2,014.50 Denying Stay to be filed in the Fourth District Court of Appeal 03/08/18 RJG Draft proposed order denying J. Epstein's Motion for 0.10 39.50 Stay of Trial Proceedings 03/08/18 RJG Revise/finalize Emergency Petition for Writ of 2.50 987.50 Mandamus to be filed in the Fourth District Court of Appeal 03/08/18 SJL Prepare for and argue at all-day special set hearing 12.50 9,375.00 on J. Epstein's Motion to Strike Matter from Trial Docket, Motion to Sever Trials, Motion to Strike Expert Dr. Jansen, Edwards' Motion to Strike Exhibits, and other issues surrounding the 27,000 page disc of e-mails located in Fowler White's files; follow up with client on outcome of hearing; follow up with Fowler White re issues surrounding disc; work on Emergency Petition for Writ of Mandamus and Emergency Motion for Review of Order Denying Stay 03/08/18 KBR Work on Emergency Petition for Writ of Mandamus 12.50 9,375.00 and Emergency Motion for Review of Order Denying Stay; work on proposed Orders for hearing; prepare for and argue at all-day special set hearing on J. Epstein's Motion to Strike Matter from Trial Docket, Motion to Sever Trials, Motion to Strike Expert Dr. Jansen, B. Edwards' Motion to Strike Exhibits and other issues surrounding the 27,000 page disc of e-mails located in Fowler White's files 03/08/18 TLC Prepare for and attend all-day special set hearing on 13.00 2,925.00 pending Motions; work on Emergency Petition for Writ of Mandamus, Emergency Motion for Review of Order Denying Stay and Appendix to same; prepare proposed Orders on B. Edwards' Motion to Sever and J. Epstein's Motion to Strike from Trial Docket; follow up with trial support EFTA00799121 Client Ref: 0002 - 0001 April 6, 2018 Invoice # 396 Page 11 Date Services Hours Amount 03/08/18 PVD [No Charge] Work on hearing binder preparation 2.00 0.00 03/08/18 PVD [No Charge] Work on deposition designations for W. 1.00 0.00 Berger 03/08/18 PVD [No Charge] Work on preparation of Appendix for 4.40 0.00 Emergency Petition for Writ of Mandamus 03/09/18 TMB [No Charge] Review Fourth District Court of Appeal's 0.10 0.00 email and Order on filing fee owed and due in ten days; review Fourth District Court of Appeal's Acknowledgment of New Case 03/09/18 CWH [No Charge] Legal research and analysis of Florida 2.30 0.00 authority and case law to determine whether general release and settlement agreement of a fee dispute can effectively waive the right to bring a malpractice claim against prior attorney 03/09/18 RJG Review 3/8/18 hearing transcript in preparation for 0.50 197.50 drafting Emergency Petition for Writ of Certiorari 03/09/18 RJG Research/review/analyze case law on certiorari 1.90 750.50 review and severance and bifurcation orders in preparation for drafting Emergency Petition for Writ of Certiorari 03/09/18 RJG Draft/revise Emergency Petition for Writ of Certiorari 4.20 1,659.00 (as to circuit court's severance order) 03/09/18 RJG Draft/rev:se Motion to Consolidate extraordinary writ 0.20 79.00 petitions filed in the Fourth District Court of Appeal 03/09/18 TLC Prepare letter to J. Hurley re evidentiary issues; 11.00 2,475.00 prepare Notice of UMC hearing on Motion for Default against S. Rothstein; prepare letter and package to appellate clerk following up on filing of Petition for Writ of Liandamus; prepare e-mail to M. Nurik re hearing, on Motion for Default; update calendar re deadline for Response and Reply; work on reviewing Fowler ' ' :kris documents for paper trail of product' . work on Juror Questionnaire; follow up with K. Tarry re same; prepare proposed Order on Motion it Amine re Sex Registry; follow up with J. Scare' s:,ine; work on Order re settlement inform..niuri EFTA00799122 Client Ref: 0002 - 0001 April 6, 2018 Invoice # 396 Page 12 Date Service• Hours Amount 03/09/18 SJL Work or• iror Questionnaire; work on Petition for 10.20 7,650.00 Writ of c rtiorari Review of Order Severing Cases; work on : °paring for trial; meet with J. Goldberger re trial str- iies; e-mails communications with J. Scarola e production and trial issues; review P. Cassell's proposed orders; e-mail communications with P. Cassell re orders and his clients' position in the case; work on opening statement 03/09/18 KBR Work o tition for Writ of Certiorari Review; 8.00 6,000.00 preps — itegy for consolidating with pending Petit! :Wit of Mandamus; consider strategy for Petiti, • 'frit of Mandamus and/or Certiorari regal' aim of privilege for e-mail documents 03/09/18 PVD [No C 4 Work on preparation of submissions to 1.00 0.00 the C Court, Fourth District Court of Appeal for Eme' • Petition for Writ of Mandamus 03/09/18 PVD [No C' ' Review production seeking billing files 1.80 0.00 for Fr . 03/09/18 PVD [No c Work on updating trial binders 0.30 0.00 03/09/18 PVD [No C Review Farmers' privilege log for emails 1.00 0.00 03/09/18 PVD [No C ' Review production for correspondence 0.40 0.00 in rai , ;:ebruary 2011 re production of disc 03/09/18 PVD [No C f Reorganize files used from production 1.50 0.00 recci n Fowler White 03/10/18 SJL Revi v 8 transcript re rulings on how to treat 5.50 4,125.00 coat zy of documents; multiple e-mails (all day) with f 'Jell and J. Scarola re same; work on ways to re agreement; work on Emergency Petition for C' work on joint letter to court re sealing recor EFTA00799123 Client Ref: 0002 - 0001 April 6, 2018 Invoice # 396 Page 13 Date Service. Hours Amount 03/10/18 KBR Legal r •-• rch regarding in camera review and 4.50 3,375.00 Petitio: Nrit of Certiorari; multiple emails with P. Casse' ' 3carola, clerk of court and A. Bormai. neral counsel for 15th Judicial Circuit; review c line 15th circuit docket; review of Fourth Distric' t of Appeal docket; revise Petition for Writ of orari regarding grant of B. Edwards' Motion eparate Trials (severance) 03/10/18 RJG Draft "! wound" section for Petition for Writ of 1.30 513.50 Certior :id revise petition to include trial court's multip' .rences to J. Epstein's original proceeding as bei :nesis" for B. Edwards' counterclaim 03/10/18 RJG Revir. s of Judicial Administration re sealing of 0.20 79.00 rector( Jpellate court 03/10/18 RJG Reviev. yze correspondence from non-party 0.20 79.00 intervel. ounsel re failure to caption them In filings with th nth District Court of Appeal 03/10/18 MLP [No Ct; ' Conduct legal research re computation 0.40 0.00 of firm :ifically analyzing Florida Rule of Judicial Admin. on 2.514, Florida Rules of Appellate Procc :nd Florida appellate courts' opinions and case arding the same in order to determine the be! rse of action in terms of timing of the briefin, :dule pursuant to the Fourth District Court of Api: 3/9/18 order 03/11/18 TLC Work c ;embling documents to seal; prepare 8.50 1,912.50 Notict :npliance, Notice of Filing disc under seal, . ;ice of Filing Exhibits under seal in order to pre. Ippeltate record; work on cleaning up heari: rs; review communications from P. Casst J. Scarola and our responses; review 3/8/11 Apt 03/11/18 SJL Work :es relating to Stay Order and sealing 5.30 3,975.00 retort.: .k on Notice of Compliance; work on Petitic ;ertiorari review 03/11/18 KBR Work :es rein:ing to Stay Order and sealing 1.20 900.00 recor 4 : on '-, g.": on for Certiorari review; follow up w' inar. . , compliance with destruction of docu , EFTA00799124 Client Ref: 0002 - 000' April 6, 2018 Invoice # 396 Page 14 Date Servie' . Hours Amount 03/12/18 RJG Final to Petition for Writ of Certiorari in 1.90 750.50 preps the Fourth District Court of Appe. n",irence with partners re same 03/12/18 RJG Begin • - 'analysis of B. Edwards' Response to 2.60 1,027.00 emery nandamus petition 03/12/18 RJG Corree ince with opposing counsel re their 0.20 79.00 agree- unopposed motion to consolidate writ petiti. ie Fourth District Court of Appeal and revisi '• 03/12/18 RJG Revic , 'I .in D. Indyke re B, Edwards' 0.20 79.00 Respi mar lay ius petition in preparation for filing i 03/12/18 RJG Revie 8 herring transcript in preparation for 0.30 118.50 draftir • ;0i'. Edwards' Response to mandamus petit', 03/12/18 TLC Work m•; 'or UMC hearing re sealing 11.30 2,542.50 recor rr 'n's timeline and prepare sums. roduction dates; prepare e-mail to J. I mo• work on assembling appendix items ..on or Certiorari review; work on Petiti( ari Review and Motion to Cons• n v 3. Edwards' Response to Petiti. ;,.1 :ndamus and Motion to Lift Stay; calct ,idnr deadlines relating to same; work I tc Motion; prepare letter to Fourth Distr ;. •' Clerk re same; continue revie ,'s boxes in order to determine chaii. ; and production by B. Edwt- exhibits 03/12/18 SJL Prep. end hearing on proposed Order 9.50 7,125.00 seali 11 !S; follow up with J. Scarola on prod. s . v, .: lc on Petition for Writ of Ceri o. 'd Consolidate Petition for Writ o
ℹ️ Document Details
SHA-256
17356e217620af04b1c1a59b99099f8b1c20b0d44e03af47d27bfb47a6fb40b9
Bates Number
EFTA00799106
Dataset
DataSet-9
Document Type
document
Pages
39

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